What changed in the EUDR under Regulation (EU) 2025/2650

Regulation (EU) 2025/2650, published on 23 December 2025, did two things: it postponed the EUDR by a year, and it removed the due diligence statement obligation from everyone except the operator who first places a product on the EU market. If you buy within the EU and sell on, you no longer file a statement — you collect and keep the reference number of the one filed upstream.

That second change is larger than the delay, and a great deal of compliance work bought in 2025 was scoped against rules that no longer apply.

The new application dates

Application moved to 30 December 2026 for large and medium operators and traders. Micro and small operators dealing in non-timber products have until 30 June 2027. Micro and small operators whose products were already within the scope of the EU Timber Regulation stay on the December 2026 date — the extension does not reach them. Which EUDR deadline applies to you sets out how the size test works.

Only the first operator files a statement

Under the original regulation, operators and non-SME traders each filed due diligence statements, producing a chain of overlapping declarations about the same consignment.

The amendment concentrates the obligation. The operator who first places the relevant product on the EU market — the importer, or the EU producer — files the due diligence statement and assumes legal responsibility for it. They receive a reference number.

Everyone downstream collects and retains that reference number instead of filing anything. It must be available to the competent authority on request and kept for five years.

Downstream operators and traders that are not SMEs must still register in the Information System, even though they no longer file. Registration is what makes the chain traceable; skipping it because you have nothing to submit is a mistake.

Where you sit	Before 2025/2650	Now
First placing on the EU market	File a due diligence statement	File a due diligence statement
Downstream operator, non-SME	File a statement	Register; collect and retain reference numbers
Downstream operator or trader, SME	Collect information	Collect and retain reference numbers

Simplifications for micro and small primary operators

Two concessions, both conditional on sourcing from countries benchmarked low risk under Implementing Regulation (EU) 2025/1093.

A micro or small primary operator sourcing only from low-risk countries may submit a single simplified declaration in the Information System, rather than a due diligence statement per consignment. And such operators may give postal codes in place of precise geolocation coordinates.

Both are meaningful. The per-consignment statement is the recurring administrative cost of the regulation, and geolocation is the requirement that most often cannot be satisfied at all.

Neither concession touches the substance: the product must still be deforestation-free after 31 December 2020 and legally produced, and you must still be able to show it.

Country benchmarking, and what it does not do

Implementing Regulation (EU) 2025/1093, in force since 22 May 2025, classified countries into three tiers. Four are high risk: Belarus, Myanmar, North Korea and Russia. Around 50 are standard risk. Roughly 140 are low risk, including all EU member states, the United Kingdom, the United States, Canada, China, Japan, Australia and South Africa.

The tier sets the intensity of official checks — 1% of operators for low-risk origins, 3% for standard, and 9% of operators plus 9% of volume for high risk — and it determines eligibility for simplified due diligence.

What it does not do is exempt anyone. A low-risk origin reduces the assessment burden; it does not remove the obligation to collect information, and it does not remove the statement for operators outside the micro/small simplification.

What did not change

It is worth being precise about this, because the volume of commentary around the delay has left an impression that the regulation was gutted. It was not.

• The seven commodities are unchanged: cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus the derived products in Annex I.
• The 31 December 2020 cut-off date is unchanged.
• Geolocation of plots is unchanged for everyone outside the micro/small low-risk simplification — polygons above 4 hectares, points below, and all establishments for cattle.
• The five-year record retention obligation is unchanged.
• The penalties are unchanged, including fines with a maximum of at least 4% of annual EU-wide turnover.
• Non-SME operators must still publish an annual due diligence report.

A review is still to come

The amendment obliges the Commission to carry out a simplification review and report on the impact and administrative burden of the regulation, particularly for smaller operators. Further change is therefore possible, and anyone planning on the basis that the current text is final should hold that view loosely.

What is not sensible is treating possible future simplification as a reason to wait. The work that takes time — mapping product lines to CN codes, and extracting production-country and plot data from suppliers — is required under every version of the regulation that has existed so far.

What to do about it

If you bought or scoped EUDR compliance work before December 2025, re-read it. Anything that has you filing due diligence statements as a downstream buyer is now wrong, and anything that has you working to a December 2025 date is a year out.

If you have not started, the sequence has not changed: classify your products by CN code, establish where you sit in the chain, then start the supplier data request, which is the part that takes months rather than weeks.

Check what the EUDR requires of your business and get a plan dated back from your application date.