The EU co-legislators (the Council and the European Parliament) have now adopted their respective positions on the European Commission’s proposed amendments to the EUDR (source: European Commission). This means they can formally enter interinstitutional negotiations (“trilogues”) to reach a final agreement.
The mandates of both co-legislators aligns on several key elements: a 12-month postponement for all operators, a range of simplification measures largely aligned with (and in some cases going beyond) the Commission proposal, and a requested review of the EUDR by April 2026 to assess impacts and the need for further adjustments. Some divergences remain however, notably, the Parliament’s proposal to exclude the printing sector from the scope of the regulation. Also, the 4th risk category (‘no risk’), which was previously proposed, is not under negotiations and will not be a matter of discussions.
Given the proximity of the two positions and the Commission’s facilitating role, negotiations are expected to be relatively smooth and to conclude within the planned timeframe — possibly during the two meetings that are currently slated for week commencing 1st December. This makes it very likely that the 12-month delay will be confirmed for all operators (pending formal approval), effectively removing the Commission’s proposed grace period for large and medium operators. Additional simplifications are also likely to be agreed, broadly consistent with the Commission’s approach. Some additional Parliament’s requests may be a matter of discussion.
The timeline remains tight: once a provisional agreement is reached, it must still be formally endorsed by both institutions — the Parliament (expected around 15 December) and the Council (expected around 18 December). Any final agreement on the changes to the EUDR needs to be published in the EU Official Journal before 30 December in order for them to come into force as intended.
The European Council Position
On 19 November 2025, the European Council (EU member countries) formally adopted a negotiating mandate to revise EUDR. Under that mandate, they propose to delay the EUDR application date for all operators, shifting enforcement to 30 December 2026 for medium/large operators and 30 June 2027 for micro and small operators.
This negotiating mandate also includes simplifications to the due-diligence process and maintaining and adding on the simplification measures originally proposed by the Commission, which include:
- the obligation and responsibility for submitting the required due diligence statement would fall exclusively on the operators who first place the product on the EU market;
- downstream operators and traders would no longer have to submit separate due diligence statements, instead the first downstream operators must keep and pass on the reference number of the initial statement;
- micro and small primary operators would submit only a one-off simplified declaration.
- micro and small primary operators would have the free choice of providing either the geolocation of the plots of land or the postal address of the plots of land or of respective establishment.
The Council also tasked the European Commission with carrying out, by 30 April 2026, a simplification review assessing the EUDR’s impact and administrative burden on operators, particularly small and micro operators. Where appropriate, the review should be accompanied by a legislative proposal.
Sources to consult: Consilium and Consilium position
The European Parliament (EP) Position
On 26 November 2025, the EP formally adopted a negotiating mandate to revise EUDR.
Under their mandate, the EP voted in favour of a one-year delay in implementing EUDR, with large companies to comply by 30 December 2026, and micro/small enterprises by 30 June 2027. The postponed date applies across the board, aligning with the European Council’s position and creating a uniform extended timeline for all operators.
This negotiating mandate also applies to simplifications to the due-diligence process, maintaining and adding on the simplification measures originally proposed by the Commission and the Council, which include:
- the onus on submitting a due diligence statement should fall on the businesses who first introduce the relevant product onto the EU market, and not the operators and traders that subsequently commercialise it;
- the micro and small primary operators would now only have to submit a one-off simplified declaration. The mandate extends on the definition of ‘micro and small primary operators’, however keeps the establishment of such entity only in a country classified as low risk;
- the micro and small primary operators would hold the free choice of providing either the geolocation of the plots of land or the postal address of the plots of land or of respective establishment;
- the EUTR shall continue to apply until 31 December 2029 to timber and timber products as defined in the EUTR that were produced before 29 June 2023 and placed on the market from 30 December 2026
- exclusion of the following products from the scope of the EUDR: printed books, newspapers, pictures and other products of the printing industry; manuscripts, typescripts and plans
The EP requested a simplification review by 30 April 2026 to assess the law’s impact and administrative burden. Where appropriate, this should be followed by a legislative proposal.
Sources to consult: European Parliament and Parliament’s adopted amendments (position)