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EUDR: Where Do We Stand After the Council and Parliament Positions?

28.11.2025

Over the past days, the revision of the EU Deforestation Regulation (EUDR) has entered a decisive phase. The Council of the European Union has adopted its negotiating mandate, followed shortly by the European Parliament’s adoption of its position.

It is important to note: none of this is final yet.
The text must now be negotiated in trilogue between the three institutions (Commission, Council and Parliament).

The choice of delay: one more year, and a little less breath

The Council Position (20 November)

The Council adopted a negotiating mandate built around three main elements:

  • A one-year postponement of the EUDR application
  • 30 December 2026 for operators and traders,
  • 30 June 2027 for micro and small enterprises.
  • Maintaining the core approach proposed by the Commission

Including:

  • a simplified regime for micro and small primary operators (MSPO),
  • the possibility to replace geolocation with a postal address in specific cases,
  • maintaining the obligation to transmit due diligence statement (DDS) reference numbers along the supply chain.
  • A simplification review clause

The Commission must carry out a review of administrative burdens by 30 April 2026, potentially followed by a new legislative proposal.

 

The European Parliament Position (27 November)

With 402 votes in favour and 250 against, the Parliament adopted a position very close to the Council’s.

  • Same postponement timeline
  • 30 December 2026 (operators and traders),
  • 30 June 2027 (micro/small enterprises).
  • Similar simplifications
  • an annual simplified declaration for MSPO,
  • lighter geolocation obligations,
  • reduced requirements for downstream operators.
  • A modification on DDS transmission

Unlike the Council:

  • the Parliament limits the transmission of DDS reference numbers to the first downstream operator only.
  • Confirmation of a simplification review (April 2026)

The review may lead to a new legislative proposal by the Commission.

What Happens to the Commission’s Initial Proposal?

Released on 21 October, it aimed to:

  • create a simplified exemption for micro/small operators in low-risk countries,
  • remove the downstream DDS obligation and replace it with reference-number transmission,
  • postpone application only for micro/small operators.

Council and Parliament have taken a different approach:

  • a general one-year postponement,
  • downstream simplification,
  • a review clause in 2026,
  • no sector-specific differentiation.

What Happens Next? The Trilogue Process

Trilogues are expected to begin next week.
Since the Council and Parliament positions are very similar, negotiations may be concluded quickly.

Next steps:

  1. First trilogue meeting (likely early December),
  2. Search for a political agreement,
  3. Publication of the final text, potentially before the end of 2025,
  4. Preparation phase for Member States and operators ahead of the new application dates.

Conclusion: A Process Still Wide Open

Nothing is decided yet.

  • Trilogue negotiations will determine the final compromise,
  • And the regulatory framework may still evolve quickly in 2026.

We will continue to monitor developments closely and update members as soon as new information becomes available.