The European Commission has proposed targeted changes to the EU Deforestation Regulation (EUDR) to ensure a smoother implementation, primarily by reducing the administrative load on smaller companies and downstream actors and allowing more time to prepare the core IT system.
Defining Company Sizes (EU Standard)
The EUDR uses the standard EU legal definitions for company size (Directive 2013/34/EU), which determine the applicable deadlines and obligations. A company must meet at least two of the three criteria below to qualify for a category.
| Company Size | Staff Headcount (Employees) | Net Turnover | OR | Balance Sheet Total |
| Micro | < 10 | ≤ €2 million | OR | ≤ €2 million |
| Small | < 50 | ≤ €10 million | OR | ≤ €10 million |
| Medium | < 250 | ≤ €50 million | OR | ≤ €43 million |
| Large | ≥250 | > €50 million | OR | > €43 million |
Note: Large companies are those that exceed the limits of the Medium category in two of the three areas.
Key Simplifications (Reducing Paperwork)
The goal is to streamline the due diligence process by focusing the reporting obligations on the first operator who places the product on the EU market.
Downstream Operators (e.g. retailers, manufacturers): Companies operating further down the supply chain will no longer be required to submit Due Diligence Statements (DDS) in the IT system. Only one submission is required at the point of entry into the EU.
Micro and Small Primary Operators (e.g. many farmers/foresters): These small businesses will benefit significantly, as they only need to submit a simple, one-off declaration in the IT system, replacing the need for regular DDS submissions.
New Implementation Deadlines (Extended Transition)
The deadlines have been adjusted, primarily to reduce the strain on the IT system, which was projected to handle a much higher load than initially anticipated.
| Company Size | Original Start Date | New Start Date | Notes |
| Micro and Small Enterprises | December 30, 2025 | December 30, 2026 | A full one-year extension. |
| Large and Medium Companies | December 30, 2025 | December 30, 2025 | Start date remains the same, but they receive a six-month grace period for enforcement and checks. |
The European Parliament and the Council must formally adopt these targeted amendments before they come into effect. The Commission is urging them to approve the proposal swiftly, ideally by the end of 2025.
Contact us directly to find out more how we can support you with EUDR

No responses yet