Wednesday, October 22, 2025
On October 21, 2025, the European Commission published a plan to revise the historic EU Deforestation Regulation (EUDR), setting the stage for a major change in the European timber industry. Widespread industry criticism of the original legislation’s alleged high administrative burden—particularly for companies farther down the supply chain—led directly to this proposed revision. Importantly, despite previous concerns for a deferral due to technological issues, the Commission has concurrently confirmed that the general application of the EUDR for large and medium-sized firms will begin as planned on December 30, 2025.
The most impactful simplification for the timber and wood packaging sectors involves a waiver of the requirement to prepare a full due diligence statement (DDS) for many companies, provided that a DDS and the corresponding EUDR reference number are already available for the raw materials they use.
The EUDR, which came into force on June 29, 2023, is designed to ensure that specific commodities, including timber, soy, palm oil, and their derived products, that are placed on or exported from the EU market are not linked to deforestation or forest degradation occurring after December 31, 2020. Since its publication, industry stakeholders have consistently voiced concerns that the stringent due diligence obligations were disproportionate to the actual risk posed by many processed timber products, leading to unnecessary administrative costs and complexity.
The Commission’s new proposal directly addresses this by streamlining requirements for downstream operators and traders—companies in the supply chain that further process or distribute a product already covered by an earlier due diligence statement.
This simplification is particularly vital for the wood packaging sector, including the manufacturers and repairers of EPAL pallets. Under the proposed amendment, these downstream companies are not required to submit their own new due diligence statements if they exclusively use wooden components (such as boards and blocks) for which a DDS and an EUDR reference number have already been secured by their suppliers.
Instead of performing and submitting an entirely new due diligence process, these companies will now primarily function as documentation custodians. Their core obligation shifts to:
This regulatory adjustment recognizes the realities of complex, multi-stage supply chains. For a product like a standard pallet, which is an assembly of already-verified wood components, requiring each subsequent manufacturer or repairer to repeat the full due diligence process would have multiplied the administrative burden exponentially without a proportional increase in environmental protection. The new system allows compliance to be proven by maintaining a clear, unbroken chain of verified, deforestation-free material documentation, leveraging the traceability efforts undertaken earlier in the supply chain.
Final countdown to December 2025
Alongside the simplification proposal, the European Commission decisively put an end to speculation regarding a further delay. An earlier proposal to postpone the application start date, which had been put forward on September 23, 2025, citing IT system difficulties, has been retracted.
The Commission has affirmed the December 30, 2025, deadline for the EUDR to become applicable for large and medium-sized enterprises. The proposal, however, does recommend granting micro and small enterprises a longer transition period, delaying their application start until December 2026. Furthermore, some reports suggest a potential six-month “grace period” for enforcement checks for large- and medium-sized companies to provide a necessary buffer as the new IT system is fully deployed.
This decision provides the much-needed regulatory certainty that the timber industry, particularly those companies that have already invested heavily in compliance systems and supply chain mapping, had been seeking. While some environmental groups have expressed concern that the simplifications for smaller operators and the six-month grace period may weaken the regulation’s immediate impact, the Commission maintains that the core principles and objectives of preventing deforestation remain intact.
Moving forward
The new focus for the timber and wood packaging industry shifts from broad, repetitive compliance exercises to the integrity and management of EUDR reference numbers. Companies must now ensure robust internal systems are in place to meticulously track and store these unique identifiers for all wood components.
By maintaining the December 2025 start date and simultaneously introducing smart simplifications, the European Commission aims to reduce the administrative load where the risk is already mitigated, while keeping the pressure on to meet the overarching goal of eliminating deforestation from the EU supply chain. The coming months will be critical for the timber industry to fully integrate these revised requirements and finalise preparations for the law’s imminent application.
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Tags: deforestation-free, due diligence, EPAL pallets, EUDR, European Deforestation Regulation, supply chain compliance
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