FESI has created an overview analysis on the revision of the European Union Deforestation Regulation (EUDR) with the final position from the Parliament, agreed last week on 26 November. Interinstitutional trilogue negotiations are expected to officially start in the upcoming days. The official four column document with the institutions' positions, together with a table of contents to facilitate navigation, is attached to this email.

MORE DETAILS

As informed in previous emails, the European Parliament and the Council have adopted their negotiating positions on the proposal for a revision of EUDR. The main changes introduced to the original proposal by the two institutions include:

• One-year postponement of the EUDR’s application. Both the Council and the Parliament ​propose large operators and traders to be required to comply with the Regulation from 30 December 2026, while micro- and small enterprises would follow from 30 June 2027. This extension is intended to give the European Commission additional time to upgrade the IT systems used for electronic due-diligence statements.

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• Simplification of due-diligence requirements for downstream operators. Under the Parliament and Council’s approach, the responsibility for submitting due-diligence statements would lie with the businesses that first place products on the EU market, thereby reducing the obligations for downstream operators and traders. Micro- and small primary operators would only need to submit a one-off simplified declaration.

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• Expansion of the definition of ''micro- and small primary operators''. This proposal from the Council would allow companies that exceed at least two of the criteria established under Directive 2013/34/EU in their overall accounts to still qualify as micro or small operators if they can demonstrate that the parts of their balance sheet total, net turnover and average number of employees during the financial year that relate to their activities covered by the Deforestation Regulation do not exceed the limits of at least two of these criteria.

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NEXT STEPS

Parliament will vote on the deal during its 15-18 December 2025 plenary session. The text agreed must be endorsed by both Parliament and Council and be published in the EU’s Official Journal before the end of 2025 for the changes to enter into force. Otherwise, the current deadlines will apply. FESI will follow up with a detailed FAQ document on the new revised Regulation as soon the official text is approved and available.