On October 22, 2025, the European Union (EU) Commission reached a deal to begin the implementation of EUDR on December 31, 2025 by issuing a targeted policy simplification for the Small and Medium Enterprises (SMEs) in the EU and the farmers producing forest commodities in the exporter countries.
This statement came out after the EU Commission previously announced a proposal on September 23, 2025 to delay the EUDR for the second time due to the then-inadequate Information Technology (IT) system which could potentially affect the due diligence process, which would be the entire point of its implementation.
Furthermore, the EU Commission also issued a proposal which explained their response related to that issue by preparing a number of suitable scenarios to ensure the IT system would be able to remain functional for data and information communication, even if imperfect.
By ensuring a timely implementation by the end of this year, the EU Commission focused on the upper-half importer corporations, with a grace period of six (6) months from the implementation date to ensure a smooth transition phase.
Meanwhile, for the operators/SMEs in the EU region and the farmers in the exporter countries, the EUDR implementation would begin on December 31, 2026.
This decision was connected with the targeted simplification for the bureaucracy among the operators/SMEs in the EU region and the farmers in the exporter countries. First of all, both groups would only need to apply for the information declaration to the IT system once, and only once, at the entry point to the EU market.
Secondly, the EU Commission would no longer demand a due diligence statement to both groups, meaning that the documents requirement would become much simpler than before.
Furthermore, according to the proposal, the importer corporations would still maintain full responsibility to ensure that the forest commodities (beef, leather, cacao, coffee, rubber, wood, palm oil) come from the deforestation-free forestry with a legal and traceable production process.
Therefore, the corporations would require to conduct a due diligence in its entirety, including risk assessment, mitigation procedures, and the delivery of the due diligence statement to the IT system for every batch of delivery.
For example, an importer company only needs to apply for a single due diligence statement to the IT system in order to deliver the products into the EU market, whereas the EU operators/SMEs that process cacao to sell as a variety of chocolate products no longer need to send the statement anymore.
Kaoem Telapak’s response to the EU Commission’s latest press release regarding EUDR
Kaoem Telapak welcomes the EU Commission’s initiative to implement the EUDR timely, especially after the previous proposal regarding a potential delay of EUDR last September which drew criticism from the public or the environment organizations in Indonesia.
Kaoem Telapak Senior Campaigner, Denny Bhatara stated, “We welcomed and much appreciated the EU upholding its commitment to the EUDR implementation, which will come into force on 31 December 2025.”
However, even though this press release appears to be good news for everyone, the EU Commission must remain committed to the EUDR by not weaking the regulation.
The EU Commission’s decision to simplify the regulation requirements for the operators/SMEs in the EU region and farmers in exporter countries shows that they choose to reduce the type of groups that need to apply the documents to the IT system in order to improve its efficiency, rather than fixing the system completely amid the remaining time.
This decision may potentially create a loophole for deregulation that weakens the EUDR’s efficacy.
Therefore, the EU Commission must ensure that the EUDR implementation will not weaken as time goes on. One strategic practice to do so is to maintain sustainable adjustment to the policy regularly without weakening its efficacy for any side involved in it.
“This is the landmark for global society that deforestation issues must be addressed and requires a collective effort, despite any challenges that may arise. Therefore, incremental improvement is indeed another objective to pursue to make this regulation more robust and ensure everyone benefits from it,” Denny concluded.
