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EUDR: A text so lightened… it has lost its sap

05.12.2025

On December 5 in Brussels, the EU Council and the European Parliament reached a political agreement in trilogue on an amended version of the EUDR.

The agreement introduces three major changes:

  1. A one-year postponement of the main implementation deadlines (6 more months for micro and small companies).
  2. A narrowing of due diligence obligations, now applying only to the first placer on the EU market.
  3. Lighter requirements for downstream operators, the first downstream operator will only need to collect a DDR number, with no additional verification or traceability duties.

Additional technical adjustments accompany these modifications, including a scheduled review in 2026.

The trilogue text will now be submitted to the European Parliament for a mid-December vote, followed by formal adoption by the Council.

This agreement represents a major shift from the initial ambition of the EUDR. It alters the balance of responsibilities within the supply chain and delays the expected enforcement timeline.

A text so lightened… it has lost its sap

It’s done.

In one hour of trilogue negotiations in Brussels, the fate of the EUDR shifted.

The Council and Parliament reached an agreement — quickly, too quickly — on a simplified, postponed, diluted version of the regulation adopted in 2023.

A text that was meant to change the game.
A text that was meant to reward 30 years of efforts by actors committed to certified sustainable management of tropical forests.
A text that was meant to send a clear signal: in Europe, access to the market means proving you are not destroying forests.

Today, that direction has blurred.

A postponement that dares not speak its name

Calling this “more time to prepare” is simply a polite way of erasing an entire year from the calendar.

Operators who were ready — and there are many — will wait.
Those who were not ready… will wait as well.

The EUDR no longer advances.
It drifts.

A simplification that dismantles more than it builds

We asked for smart simplification: reduce unnecessary burdens, stabilise TRACES, harmonise procedures, avoid document inflation.

Instead, we get a simplification that cuts into the very structure of the regulation:

  • Due diligence focused solely on the first placer on the market.
  • The first downstream operator reduced to collecting a DDR number.
  • And beyond that… silence. No signal, no requirement, no responsibility.

A trace… without traceability.
A duty… without diligence.
A regulation… without a chain.

A paradox that is hard to understand

Simplify now.
Revise in April 2026.
Rewrite again afterwards.

How can we revise a regulation before it has even been applied?
How can we “assess an administrative burden” that has never existed?
How can we hope for stable implementation when the rules are rewritten before they are lived?

It is regulatory vertigo.
And a discreet retreat.

An engaged sector left stranded mid-stream

Tropical forest concessions with certification represent 13 million hectares of sustainably managed forests in Congo Basin — nearly the size of France’s forest area.

They expected recognition from the EUDR.
Today, they see dilution

First placers on the market — importers, European forest operators — will carry the entire burden.
Downstream actors, meanwhile, are largely relieved of responsibility.

A distortion no one can justify, and everyone will pay for: the credibility of the system, the coherence of the market, and the virtuous operators themselves.

The EUDR did not need dismantling

It needed adjustment.
It needed stabilisation.
It needed support.

The version that emerged from the trilogue is not catastrophic — it is worse.
It is incoherent.
Unfinished.
Blind to its own objectives.

What now?

Parliament will vote in mid-December.
The Council will follow.
The text will become law.

Nothing is entirely settled yet, even if the orientation now seems fixed.

In this context, the challenge is no longer only to debate the content of the revision, but to ensure that the EUDR, in its implementation, remains worthy of the expectations and investments of the sector.

The tropical forest–wood sector is ready to apply the regulation, in its final form, with professionalism and transparency.

 

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