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After weeks of uncertainty, the European Commission has released its official proposal to delay and amend key elements of the EU Deforestation Regulation (EUDR).
Beyond the potential EUDR delay that was widely discussed, the proposal contains substantial changes to the regulation text itself.
The EU Commission aims to reduce administrative burden, simplify reporting, and ensure the EU Information System (TRACES NT) can function reliably, without weakening the environmental objectives.
These are the key changes proposed:
Downstream operators are introduced as a separate category and will have the same obligations as traders.
For both traders and downstream operators, the obligation to ascertain due diligence and to submit a due diligence statement (DDS) is removed.
They still need to ensure full traceability by collecting and passing on reference numbers and declaration identifiers.
A new definition applies when the operator is:
Instead, they must submit a one-time simplified declaration in the information system.
Geolocation data can be replaced by the postal address of the plots.
This constitutes a major simplification for small primary producers based in the EU.
This leads to fewer DDS submissions and lower administrative burden.
The new timeline and postponement of penalties give companies more time to adapt to the new EUDR requirements.
The review date for changes or extensions of the scope (such as added commodities) of the EUDR has been moved to 30 June 2030.
This allows the EU Commission to evaluate the EUDR scope and requirements after the actual implementation and enforcement.
The original document containing the proposal can be found here.
While the timing and communication of the new updates were chaotic, the proposed amendments would meaningfully reduce unnecessary DDS exchanges along the supply chain and lower the burden for smaller companies, while keeping core EUDR goals intact.
Companies should be aware that this is just a proposal; it is not yet legally binding. The proposal needs to be approved by both the Council of the European Union and the European Parliament.

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Caroline is an experienced data scientist with a management degree from TU Munich and a degree in earth observation from the University of Würzburg, which is co-chaired by the German Aerospace Center (DLR). She has worked as a data scientist in the areas of nature conservation and land use change monitoring at WWF, the German Centre for Integrative Biodiversity Research (iDiv), and at tech companies such as Celonis and Deloitte.