EUDR Amendment: Trilogue Result Achieved

On 21 October 2025, the Commission published a legislative proposal to amend the EU Deforestation Regulation (EU) 2023/1115 (EUDR). More detailed information on the Commission's proposal can be found in our blog post of 22 October (available here). The Council of Ministers and the European Parliament have now reached a provisional political agreement on the future content of the Regulation in informal trilogue negotiations. The agreement gives a good indication of the likely final content of the EUDR amendment.

The most important changes in detail:

Does the agreement differ from the Commission's original proposal?

The agreement incorporates many – but not all – of the Commission's proposals. It also contains new provisions.

The following elements of the Commission's original proposal remain in the agreement:

• Continuation of existing obligations for ‘upstream operators’ (i.e. importers or first distributors of relevant products).
• Traders and downstream operators are exempt from the obligation to draw up due diligence statements.
• Introduction and privileging of ‘micro and small primary operators’ as upstream operators from a low-risk country who produce the raw material underlying a relevant product themselves. They only must submit a single ‘simplified declaration’.

The agreement contains the following new features:

• Removal of printed paper products from the scope of the EUDR.
• Postponement of the date of application of the EUDR by one year.
• No obligation for traders and downstream operators to pass on information in the supply chain.
• Introduction of a ‘simplification-review clause’.

What is the consequence of printed paper products being excluded from the scope of the EUDR?

Currently, ‘printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper’, which fall under heading 4421 49 of the Combined Nomenclature, are relevant products within the meaning of Annex I EUDR. They therefore fall within the scope of the Regulation.

Following a proposal by the European Parliament, the reference to products falling under heading 4421 49 of the Combined Nomenclature is now being removed from Annex I to the EUDR. As a result, the EUDR no longer applies to such products.

This means that economic operators trading in relevant printed paper products, such as books or advertising brochures, are excluded from the scope of the EUDR.

How will traders and downstream operators be relieved?

The Commission's proposal provided that traders and downstream operators would no longer be required to submit due diligence statements but would still have to pass on information to their customers regarding the due diligence statements relating to the relevant products they supply. This led to concerns that a significant amount of information would have to be passed on for relevant products consisting of a large number of relevant products or for large deliveries of relevant products. Following the agreement, traders and downstream operators are no longer required to pass on information to their customers.

What are the consequences of the introduction of the new ‘simplification-review clause’?

As a result of the newly introduced ‘simplification-review clause’, the Commission is obliged to assess further potential for simplification of the EUDR by 30 April 2026 and to draw up a report on this. If necessary, this report should be accompanied by a further proposal from the Commission for an amendment to the EUDR. It is therefore possible that the EUDR will be amended again in the course of 2026.

How should the outcome of the trilogue be assessed?

The one-year postponement of the date of application of the Regulation gives the economic operators concerned sufficient time to adapt to the (very) short-term changes to the EUDR and to adjust their compliance processes. The removal of the obligation for traders and downstream operators to pass on information is also likely to significantly ease the burden on them.

However, the review clause raises questions. This clause makes further amendments to the EUDR highly likely. This complicates the implementation of the Regulation by market participants. They must expect that their obligations under the EUDR will change further in the course of 2026.