Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
- New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
- Simplified DDS: One-time declarations for small and micro primary producers
- Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
- New DDS requirement: Estimated annual quantity of regulated products must be included
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
Businesses are increasingly turning their focus to reducing Scope 3 emissions – which make up 88% of total business emissions. An industry-wide problem is that scope 3 emissions are particularly challenging to manage as they occur outside a company's direct operations, spanning the entire value chain from upstream to downstream activities.
Organizations face significant hurdles in tackling Scope 3 emissions, stemming from issues such as poor data quality and availability, varied disclosure standards, and the limited integration of emissions data into core business processes. The lack of high-quality primary data from supply chain partners, especially smaller businesses, hampers accurate measurement and reporting.
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