The Official Journal of the European Union has recently published Regulation (EU) 2025/2650, which substantially amends the widely watched EU Regulation on Deforestation-free Products (EU) 2023/1115. While preserving its core environmental objectives, this revision significantly reduces compliance burdens for businesses and postpones the full implementation date by one year.文章源自FOFCC-http://fofcc.org.cn/en/33148/
Key Adjustments: Simplification and PostponementThis amendment primarily addresses industry concerns regarding regulatory complexity and tight implementation timelines. Although it maintains the fundamental goal of preventing products linked to deforestation and forest degradation from entering the EU market, the revised regulation introduces greater flexibility in compliance pathways. Crucially, the applicability date for key provisions has been pushed back from 30 December 2025 to 30 December 2026, granting small and medium-sized enterprises (SMEs) additional time to adapt.文章源自FOFCC-http://fofcc.org.cn/en/33148/
Three Major Simplifications Benefiting Businesses文章源自FOFCC-http://fofcc.org.cn/en/33148/
1. Introduction of New Operator CategoriesThe regulation creates two new categories—“downstream operators” and “micro/small primary operators”—each subject to simplified compliance requirements: Downstream Operators: Enterprises that reprocess products already cleared through due diligence no longer need to submit duplicate due diligence declarations; they only need to retain relevant documentation for inspection. Micro/Small Primary Operators: Small businesses producing and selling goods domestically in low-risk countries may submit a one-time simplified declaration, dramatically reducing administrative burdens.文章源自FOFCC-http://fofcc.org.cn/en/33148/
2. More Practical Compliance RequirementsFlexible Geographic Information: Postal addresses may now be used instead of precise geocoordinates, lowering technical barriers for micro and small enterprises. Streamlined Documentation: Downstream companies in the supply chain only need to retain the due diligence declaration reference number, eliminating the need to conduct redundant risk assessments文章源自FOFCC-http://fofcc.org.cn/en/33148/
3. Risk-Based Adjustment of Inspection RatesThe regulation refines inspection protocols by establishing differentiated inspection rates based on country-specific deforestation risk levels, enabling more efficient allocation of regulatory resources. Implications and Recommendations for Businesses For Large Enterprises: Compliance obligations remain stringent. Companies must continue strengthening supply chain traceability systems, though the new tiered management tools can help optimize compliance costs. For SMEs, especially micro-producers in low-risk countries: Compliance has become significantly easier. These businesses should proactively review eligibility criteria and simplified procedures for “micro/small primary operators.” For All Affected Companies: The one-year extension provides a valuable window to enhance internal management systems and familiarize themselves with updated operational procedures under the revised rules.文章源自FOFCC-http://fofcc.org.cn/en/33148/
Looking AheadThe European Commission will complete a simplification review by 30 April 2026 to evaluate the practical impact of these changes. This revision reflects the EU’s effort to strike a balance between environmental ambitions and commercial realities. Whether further adjustments will follow remains an issue to watch closely.文章源自FOFCC-http://fofcc.org.cn/en/33148/
[This article is based on an interpretation of Regulation (EU) 2025/2650 published in the Official Journal of the European Union and is provided for informational purposes only; it does not constitute legal advice.]文章源自FOFCC-http://fofcc.org.cn/en/33148/
2025.12.24文章源自FOFCC-http://fofcc.org.cn/en/33148/
