Brussels, 18 December 2025 - FEDIOL, representing the EU vegetable oils and protein meal industry, is pleased that the European Parliament and Council managed to adopt their provisional agreement on the Commission’s proposal for the revised EU Deforestation Regulation (EUDR) but cautions that the work to address all pending implementation issues is far from over. The Commission and Member States will have to accelerate efforts to clarify, simplify, and harmonise implementation to ensure readiness by 30 December 2026.

Much-needed solutions for several critical provisions for implementation have not been found during the 1-year postponement provided last year, which means simplification and clarification efforts through FAQs and guidelines have not yet delivered sufficiently effective and workable results. We therefore urge the Commission and Member States to address remaining problems within the first months of 2026. If no solutions can be found within the legal boundaries of the existing text, we call on the Commission to propose a targeted legislative revision of the EUDR by April 2026, as part of its simplification review, so that no gaps or bottlenecks remain by the time of the new date of application. In the case the Commission publishes a Proposal for a targeted revision of EUDR, we would also count on the European Parliament and Council to reach an agreement on the necessary changes and adopt them a few months ahead of the new date of entry into application to avoid legal uncertainty.

We have repeatedly highlighted the need for urgent solutions on various aspects of implementation, including compliance with the national legislation of producing/sourcing countries, which would require a riskbased approach in showing compliance and certainty as to the type of evidence that should be provided. Current experience with national competent authorities during dry runs has revealed a lack of harmonised interpretation and implementation across Member States as well as disproportionately strict thresholds of evidence.

Despite the proposed simplifications for downstream operators, the Information System remains unworkable for submissions of due diligence statements by (upstream) bulk operators, particularly due to the 25 MB size limitation and the burdensome workarounds suggested by the Commission.   

The Information System needs to adapt to business reality, whereas at the moment, it is business practice that has to adjust to the system.

Furthermore, a more meaningful and applicable recognition of the merits of national and private certification and permitting schemes with robust verification controls needs to be provided for in the Regulation to support operators’ efforts to make a determination of negligible risk.

FEDIOL and its members will continue to offer its support in the implementation work of the Commission and Member States by proposing solutions and highlighting areas of the legislation that still require further clarification.