Overview
The European Union has adopted Regulation (EU) 2025/2650, introducing targeted amendments to the EU’s landmark Deforestation Regulation (EU) 2023/1115. The update aims to simplify compliance obligations for operators and traders, particularly small and micro-sized businesses, while preserving the regulation’s core environmental objectives.
The original framework ensures that certain products placed on or exported from the EU market are deforestation-free, legally produced, and subject to due diligence controls. The latest amendment focuses on improving practical implementation without weakening environmental safeguards.
Objectives of the Amendment
a. Reduced Administrative Burden
The Regulation eases reporting and procedural requirements, addressing concerns raised by businesses about complexity and compliance costs—especially for smaller operators.
b. Clearer Supply Chain Roles
New definitions clarify responsibilities across the supply chain, distinguishing between downstream operators and micro or small primary operators to reflect real-world business practices.
c. Continued Environmental Protection
Despite procedural simplifications, the Regulation maintains robust traceability and due diligence mechanisms to prevent deforestation-linked products from entering the EU market.
What Has Changed?
New Definitions Introduced
- Downstream Operators:
- Supply-chain actors handling products already covered by a due diligence statement, without responsibility for the original declaration.
- Micro and Small Primary Operators:
- Smaller producers placing their own products on the market, now subject to proportionate and simplified reporting requirements.
Simplification Measures
i. Fewer Reporting Obligations
Certain operators and traders will face reduced interaction with the EU due diligence information system, lowering administrative workload.
ii. Flexible Data Requirements
Micro and small primary operators may submit postal address details instead of precise geolocation data, easing compliance while maintaining oversight.
Review Timeline and Next Steps
- Intermediate Commission Report:
- Due by 30 April 2026, assessing administrative burden and impacts, particularly on micro and small operators.
- Comprehensive Review:
- Scheduled for 30 June 2030, based on implementation experience and enforcement outcomes of Regulation (EU) 2023/1115.
Why does this matter for businesses?
- Greater clarity and proportionality in compliance obligations
- Reduced regulatory friction for SMEs and small producers
- Continued alignment with EU environmental and sustainability goals
- Increased certainty on future regulatory reviews and adjustments
Reach out to our regulation experts on chemical and product regulatory compliances