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Obligations on EU businesses trading in EUDR in-scope
commodities (including timber) are also changing. Those of small
and micro-businesses in particular are significantly simplified. European Wilderness Society
European timber trade bodies have welcomed the EU’s
action.
In October 2025, a number had joined organisations

representing other affected commodity sectors in signing an
‘open statement’ urging politicians to ‘stop the clock’ on the
EUDR and push implementation back.
They included the European Timber Trade Federation, the
CEI-Bois Confederation of European Woodworking Industries, commodities on the EU market called ‘micro or small primary
the European Organisation of Sawmill Industries, European operators’.
Panel Federation and European Parquet Federation. Such businesses, it says, should only have to submit a
A key consideration behind the amending regulation was ‘one-time simplified declaration’ in the information system.
the administrative burden the EUDR would have imposed on They would then be issued with a ‘declaration identifier’ to

companies in its original form, notably smaller firms. Another accompany relevant products they place on or export from
was the capacity of the ‘Traces’ information system, to which the EU market.
affected businesses will upload compliance data.
On the latter, the amendment regulation states that ‘most EUDR changes in summary
recent projections on the number of expected operations and • Enforcement of the EUDR for large and medium-sized in-
interactions in the information system have led to a substantial scope first placing operators will start on 30 December 2026
reassessment of the load on the system, indicating much and 30 June 2027, for micro and small primary operators.

higher traffic than anticipated.” • Only operators first placing products on the market will have
Regarding the burden on businesses of compliance, to submit due diligence statements to the EUDR information
it points to a 2024 report titled “The future of European system.
competitiveness”. • Only first downstream operators will have to keep and
“This indicated that the increasing number and complexity pass on the reference number of the initial due diligence
of rules is limiting room for manoeuvre for EU businesses statement.
and preventing them from remaining competitive,” states the • Micro and small primary operators will be able submit
amending regulation. a one-off simplified declaration to the EUDR information
“Concerns about the complexity of rules have also been system.

reported by trade partners. Against that background, certain • Micro and small primary operators will have the option to
procedures and requirements laid down in the EUDR ((EU) replace geolocation information for the source of goods
2023/1115) should be simplified and unnecessary regulatory with the postal address of the plot of land or establishment
burdens for businesses should be removed, while maintaining where they originated.
[EUDR] objectives.” • The definition of micro and small primary operators will be
The EUDR amended regulation consequently introduces a broadened. FDM
new sub-category of in scope businesses that place affected ENQUIRY NO. 1101