Regulation (EU) 2025/2650 as regards certain obligations of operators and traders

Jurisdiction: EU

Commencement: 22nd December 2025

Amends: Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation (EUDR)

 

Mini Summary

Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation (EUDR) establishes rules for commodities (e.g. cattle, cocoa, coffee, oil palm, rubber, soya and wood) and products associated with them (e.g. palm oil) that are placed on the European Union (EU) market or exported from the EU. This is to minimise the EU’s contribution to global deforestation and forest degradation and consequently, reduce greenhouse gas emissions and biodiversity loss.
 

Duties

Various duties apply and are available to view on the Legislation Update Service.

 

Amendment

The date of application for the EU Deforestation Regulation (EUDR) and repeal of Regulation (EU) 995/2010 laying down the obligations of operators who place timber and timber products on the market is postponed to 30th December 2026. EUDR requirements for micro and small enterprises (SMEs) is postponed until 30th June 2027.

Micro and small undertakings are those that do not exceed 2 of the following criteria.

  • Balance sheet total of €5 million.
  • Net turnover of €10 million.
  • Average of 50 employees during the financial year.

Changes are made to differentiate between ‘operators’ and ‘downstream operators’.

*Downstream operators are those placing products on the market which are already covered by a due diligence statement and are not required to complete a full due diligence statement themselves.

Downstream operators, excluding SMEs, must:

  • register before placing products covered by EUDR on the market or exporting them; and
  • retain information on operators, downstream operators and traders who have supplied them with EUDR products, or that they have supplied with EUDR products for 5 years.

Micro and small primary operators are excluded from full declaration requirements and instead must submit a one-time simplified declaration in the register before placing EUDR products on the market or exporting them. Operators that are a microenterprise may mandate that the next downstream operator or trader further down the supply chain acts as an authorised representative for products, providing that they are not an individual or microenterprise.

Microenterprises are those that do not exceed 2 of the following criteria.

  • Balance sheet total of €450,000.
  • Net turnover of €900,000.
  • Average of 10 employees during the financial year.

*Halon 1211 is used in fire extinguishers, especially for objects which may be damaged by residues of other extinguishers.

The new end dates are:

  • 30th June 2027 for Defence aircraft in Table 1 of Schedule 1;
  • 31st December 2040 for Defence aircraft in Table 2 of Schedule 1; and
  • 31st December 2026 for Loganair aircraft.

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