On 13. November, the European Parliament adopted the urgency procedure for the revision of the EUDR, after the Commission published a proposal for amendments mid-Oktober. However, there is no agreement between the three co-legislators, the Commission, Parliament, and Council, yet.

The most important changes in the proposal, which was surprisingly published by the Commission in mid-October, are:

• For medium-sized and large companies, start date remain on 30 December 2025, but with a 6-month grace period without checks and penalties.
• Only the first distributor in the EU will be required to complete a DDS; all downstream operators will only have to collect DDS numbers.
• For small primary operators from low-risk countries (i.e. EU farmers), simplified DDS are proposed. If a national farm data system exists covering all the relevant information, the DDS should be created by the respective member state and the farmer will then receive a confirmation number.

The Parliament will adopt its position during the plenary session from 24-27 November. It seems a majority is not in favour of the Commission’s proposal but wants to go even further in terms of simplifications and postponement.

The Council’s position does not correspond with the Commission’s proposals either. As it will be very difficult to reach an agreement in the short term, the Council’s main demand is to postpone the start date of the EUDR for all companies by a whole year.

The co-legislators will be aiming for any kind of agreement before the end of the year in order to prevent that companies must apply the EUDR requirements from 30 December onwards. If no agreement is reached in time, the current version of the EUDR remains valid – meaning that the EUDR would apply as planned from 30 December 2025, without any grace period and with due diligence obligations also for downstream operators.

The bottom line: Anyone counting on a delay is taking an operational risk. The recommendation for companies is clear – stay on course and continue preparing for implementation by December 2025. If the regulation is eventually postponed, the only “risk” is being ahead of schedule – and that is far safer than being unprepared. The path to EUDR may be uneven, but we are ready. Reach us out to find out how Donau Soja’s EUDR solution: Crop Insights can help you to get there faster – with reliable support at every step.