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ARTICLE · 30 OCTOBER 2025

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Proposed Amendments To EUDR For Downstream Supply Chains

The European Commission has proposed targeted amendments to the EU Deforestation Regulation (EUDR) to streamline implementation for downstream operators and traders, and for micro- and small undertakings...

IrelandCorporate/Commercial Law

The European Commission has proposed targeted amendments to the EU Deforestation Regulation (EUDR) to streamline implementation for downstream operators and traders, and for micro- and small undertakings, while preserving full due diligence obligations at the point where products are first placed on the EU market.

The EUDR aims to tackle deforestation and forest degradation by regulating the placement and export of certain products within the EU market. It imposes supply chain due diligence obligations on operators and traders of relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and specified derived products.

Key Proposed Changes:

  • Downstream operators and traders—such as retailers and large manufacturers who sell EUDR-relevant products after they enter the EU market would not be required to submit due diligence statements. One submission from the upstream operator at the initial EU entry point would cover the entire supply chain.

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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