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EUDR: Regulatory Analysis of the Reform Introduced by Regulation (EU) 2025/2650
- Daniel Jiménez
- 36 minutes ago
- 4 min read
The publication of Regulation (EU) 2025/2650 in the Official Journal of the European Union marks a significant point in the operational evolution of the Regulation on deforestation-free products (EUDR – Regulation (EU) 2023/1115).
Although the amendment does not alter the fundamental objectives of the regulations — to prevent products linked to deforestation from entering or leaving the European market — it does introduce significant changes in application deadlines, material scope and distribution of obligations within supply chains.
From a compliance perspective, the key element is not just the time delay, but the regulatory signal on how the European Union intends to balance sustainability, traceability and operational viability for economic operators.
Table of contents
Regulatory Context: Operational Simplification without Change in Regulatory Objective
The revision adopted by the EU Council aims to facilitate the practical implementation of the EUDR, while maintaining its environmental purpose intact: ensuring that certain raw materials and derived products are not linked to deforestation or forest degradation.
The amendment primarily addresses concerns expressed by Member States and economic actors regarding:
the administrative burden of the due diligence system
the level of preparedness of the authorities and operators
the operational availability of the European computer system
The result is an “operational”, not structural, review: application mechanisms are adjusted without modifying the core of the regulatory model.
Calendar Adjustment: Delay for Implementation, Not for Objectives
One of the most relevant changes is the postponement of the effective application of the main obligations.
The new schedule sets the application from:
December 30, 2026 for larger operators and companies
June 30, 2027 for micro and small businesses existing as of December 31, 2024
This delay aims to allow for the adaptation of IT systems, internal processes, and traceability mechanisms in both operators and public administrations.
From a regulatory point of view, this type of delay usually indicates a pragmatic approach: ensuring effective compliance rather than premature formal implementation.
Modification of Material Scope: Exclusion of Printed Products
The reform also introduces a specific modification to the scope of Annex I, eliminating certain products associated with Chapter 49 of the tariff system, including books, newspapers and other printed products.
This exclusion is based on the assessment of the low risk of deforestation associated with these products and aligns with the objective of concentrating regulatory resources on commodities with a real impact on global deforestation.
For the publishing and printing sectors, this amendment provides direct legal certainty by formally excluding them from the EUDR due diligence regime.
Redistribution of Responsibilities in the Supply Chain
The amendment also clarifies the distribution of obligations among actors in the chain.
The model maintains the primary responsibility for due diligence on operators who introduce the product to the market, while downstream actors maintain obligations mainly related to traceability and information, reducing administrative duplication.
In regulatory terms, this reflects an increasingly visible trend in European legislation: centralizing critical obligations at key market entry points, while maintaining traceability obligations for the rest of the chain.
Specific Simplification for Small Primary Operators
The reform also introduces simplified mechanisms for micro and small primary operators, including simplified declaration options and more flexible geolocation requirements under certain conditions.
This approach reflects the legislative effort to reduce disproportionate regulatory barriers for smaller operators without weakening the global traceability system.
Strategic Reading: What Regulatory Signal Is the EU Sending
From a regulatory intelligence perspective, the message is twofold:
On the one hand, the EU reaffirms the political and environmental objective of the EUDR. On the other, it recognizes the global operational complexity of implementing forest traceability systems on an international scale.
The amendment also introduces the obligation of future review of the administrative impact of the regulation, including a specific assessment of the burden on small operators.
This suggests that the EUDR will continue to evolve in progressive phases.
Practical Impact for Businesses
The temporary delay should not be interpreted as a regulatory pause.
The EUDR continues to require, in the medium term:
complete supply chain mapping
robust traceability systems
verifiable data governance
internal processes aligned with environmental due diligence
The European regulatory approach remains clearly focused on controlling environmental risk throughout the value chain.
Regulatory Conclusion
Regulation (EU) 2025/2650 does not redefine the EUDR, but it does redefine its practical implementation.
From a compliance perspective, the most relevant change is not the time delay, but the confirmation of a regulatory model based on:
full traceability
responsibility structured by levels of the chain
progressive risk-based supervision
The EUDR remains, in essence, one of the most demanding environmental traceability regulations globally.
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