Another Revision of the EUDR: What Should Ukrainian Exporters Prepare for?

The European Union ("EU”) has already once again amended the EU Regulation on the Prevention of Deforestation ("EUDR”). On December 17, the European Parliament ("Parliament”) and on December 18, the Council of the EU, formally adopted a new Regulation amending certain obligations of market operators under the EUDR and postponing the start of its application ("revised EUDR”). The revised EUDR entered into force on December 26, 2025, three days after its official publication in the Official Journal of the European Union.[1]

Recall that the EU introduced the EUDR back in 2023. Initially, it was supposed to come into force on December 30, 2024. Still in October last year, the deadline was extended by one year for most market operators (until December 30, 2025) and by a year and a half for small businesses (June 30, 2026). Not only were deadlines revised, but also material requirements for manufacturers and exporters. In our publication, Measures to simplify the implementation of the EUDR announced, we have already analysed the innovations proposed by the European Commission ("Commission”) in April – May 2025.

The EUDR requires that each batch of products be accompanied by a due diligence declaration. Previously, all enterprises in the supply chain had to do this; the simplified regime applied only to micro, small, and medium-sized enterprises. From now on, downstream operators and traders are also exempt from this obligation, and will only have to provide information if available. The revised EUDR shifts the focus to the companies that are the first to supply products to the EU market, i.e. the exporter/manufacturer. This is especially true for Ukrainian companies, because even if they sell their raw materials to traders, this does not exempt them from the obligation to submit an appropriate declaration. Such market operators must also maintain traceability by collecting reference numbers, due diligence statements, and declaration identifiers assigned to micro and small manufacturers.

The simplifications for micro and small enterprises are that the simplified declaration will now be submitted by them only once. Such businesses will be exempt from the obligation to update information in the future, unless there have been significant changes to the product or other information.

Another significant simplification for such companies is the ability to replace geolocation information with postal addresses. Moreover, they will have a free choice between the postal address of the land plot or the postal address of the enterprise where the relevant products contained in the relevant product were produced or were used to make it.

In addition, the category of "micro and small market operators” will be significantly expanded. Now it also includes enterprises that will be able to prove that parts of their balance sheet, net turnover and average number of employees related to their activities exclusively within the EUDR do not exceed the limit defined in Articles 3(1) and (2) of Directive (EU) 2013/34/EU, which actually establishes the criteria for classifying enterprises as "micro and small enterprises”. The category will also include individuals, but, as with small businesses, they must be from low-risk countries in accordance with Art. 29 EUDR (Ukraine is included).

Another simplification concerns the list of products covered by the revised EUDR. Some printed products should be excluded from its scope, namely printed books, newspapers, illustrations, and other products of the printing industry, manuscripts, typescripts, and plans made of paper.

The application of the EUDR will again be postponed for one year (until December 30, 2026) for large market operators, and for one and a half years (until June 30, 2027) for micro and small enterprises. Moreover, the Commission has until 30 April 2026 to revise the EUDR and submit it to the Council of the EU and the Parliament, together with a possible legislative proposal.

Obviously, the changes to the EUDR and the postponement of its application are a response to the additional difficulties that its implementation entails not only for businesses and governments, but also for the EU itself. In particular, the previous agreement on the revised EUDR explicitly states that the EU has faced technical problems documenting information in its system due to increased workload.[2] Nevertheless, this does not mean that enterprises, including Ukrainian exporters, should not prepare for the new procedures now. The next year should be devoted to:

[1] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32025R2650&qid=1767618043280

[2] https://www.consilium.europa.eu/media/x51ho5p5/text-provisional-agreement-eudr-revision-dec-2025.pdf