P10_TA(2025)0295Deforestation Regulation: certain obligations of operators and traders Amendments adopted by the European Parliament on 26 November 2025 on the proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders (COM(2025)0652 – C10-0263/2025 – 2025/0329(COD)) The matter was referred back for interinstitutional negotiations to the committee responsible, pursuant to Rule 60(4), fourth subparagraph.(Ordinary legislative procedure: first reading)Text proposed by the CommissionAmendmentAmendments 39, 66 and 102Proposal for a regulationRecital 6

(6)Non-SME downstream operators and traders have a significant influence on supply chains and play an important role in ensuring that supply chains are deforestation-free. They should, therefore, still be required to register in the information system. At the same time, all downstream operators or traders, whether or not they are SMEs, should continue to ensure full traceability by collecting and passing on reference numbers of due diligence statements and declaration identifiers assigned to micro and small producers.

(6)Non-SME downstream operators and traders have a significant influence on supply chains and play an important role in ensuring that supply chains are deforestation-free. They should, therefore, still be required to register in the information system. At the same time, first downstream operators or traders, whether or not they are SMEs, should continue to ensure full traceability by collecting reference numbers of due diligence statements and declaration identifiers assigned to micro and small producers. This obligation to collect and keep reference numbers should only apply to the first down-stream operator and should not apply to all others down-stream operators further down in the supply chain.

Amendments 40, 67 and 103Proposal for a regulationRecital 7

(7)All operators, regardless of their size, placing relevant products on the market or exporting them fall under the scope of Regulation (EU) 2023/1115. This places an administrative burden on micro and small producers who place on the market or export their own products. In order to address the concerns related to micro- and small-sized operators producing and placing on the market their own products and to further reduce the load of the information system, it is necessary to introduce a new sub-category of operators to whom the obligation to submit a due diligence statement should not apply. This new subcategory, called ‘micro and small primary operators’, should cover natural persons or micro- or small-sized enterprises established in a country classified as low risk in accordance with Article 29 of this Regulation placing relevant products on the market or exporting them which they themselves produce, meaning that they grow, harvest, obtain from or raise the relevant commodities contained in relevant products themselves. Both operators established within and outside of the Union should be covered by the definition of micro and small primary operator.

(7)All operators, regardless of their size, placing relevant products on the market or exporting them fall under the scope of Regulation (EU) 2023/1115. This places an administrative burden on micro and small producers who place on the market or export their own products. In order to address the concerns related to micro- and small-sized operators producing and placing on the market their own products and to further reduce the load of the information system, it is necessary to introduce a new sub-category of operators to whom the obligation to submit a due diligence statement should not apply. This new subcategory, called ‘micro and small primary operators’, should cover natural persons or micro- or small-sized enterprises established in a country classified as low risk in accordance with Article 29 of this Regulation placing relevant products on the market or exporting them which they themselves produce in that country, meaning that they grow, harvest, obtain from or raise the relevant commodities contained in relevant products themselves. Both operators established within and outside of the Union should be covered by the definition of micro and small primary operator.

Amendments 41 and 68Proposal for a regulationRecital 8 a (new)

(8a)Furthermore, as part of the simplification efforts, the administrative burden resulting from the obligations for micro and small primary operators to submit a one-time simplified declaration under Article 4a and to collect information under Article 9(1) should be reduced by allowing them to replace the geolocation of plots of land by the postal address of the plots of land or of the establishment from where the relevant commodities that the relevant product contains, or has been made using, were produced, provided that the postal address clearly corresponds to the geographic location of the plots or establishment concerned. This gives micro and small primary operators the free choice of providing either the geolocation of the plots of land or the postal address of the plots of land or of respective establishment.

Amendment 105Proposal for a regulationRecital 11

(11)To provide legal clarity that all micro, small and medium-sized undertakings, irrespective of their legal form, can benefit from the simplified provisions for micro small and medium-sized enterprises in Regulation (EU) 2023/1115, the definition of micro, small and medium-sized enterprises should be amended to clarify that the legal form should not be relevant for whether a natural or legal person meets the definition. The same should be clarified for micro and small primary operators.

(11)To provide legal clarity that all micro, small and medium-sized undertakings, irrespective of their legal form, can benefit from the simplified provisions for micro small and medium-sized enterprises in Regulation (EU) 2023/1115, the definition of micro, small and medium-sized enterprises should be amended to clarify that the legal form should not be relevant for whether a natural or legal person meets the definition. The same should be clarified for micro and small primary operators. Moreover, the definition of micro and small primary operators should include operators who exceed the limits of at least two of the three criteria set out in Article 3(1) and (2), first subparagraph, of Directive 2013/34/EU but who can demonstrate that the parts of their balance sheet total, net turnover and average number of employees during the financial year which relate to their activities covered by this Regulation do not exceed the limits of at least two of three of those criteria.

Amendment 106Proposal for a regulationRecital 12 a (new)

(12a)Ahead of the general review of Regulation (EU) 2023/1115 to be carried out by 30 June 2030, in the interest of simplification for operators and traders, the Commission should carry out a simplification review of Regulation (EU) 2023/1115 and should present a report by 30 April 2026. The report should evaluate the administrative burden and impact of this Regulation, in particular for micro and small operators. Furthermore, in the report, the Commission should indicate possible ways to address the identified issues, including through technical guidelines, improvements to the IT-system, delegated or implementing acts in accordance with the delegated powers provided for in the Regulation and, where appropriate, accompany the report with a legislative proposal.

Amendment 107Proposal for a regulationRecital 12 b (new)

(12b)The date of application of the provisions of Regulation (EU) 2023/1115 that lay down obligations on operators, traders and competent authorities, listed in Article 38(2) of that Regulation, should be postponed by 12 months. This is necessary in order to allow third countries, Member States, operators and traders to be fully prepared, including, to allow those operators and traders to establish the necessary due diligence systems covering all relevant commodities and products, so as to be in a position to fully comply with their obligations.

Amendment 108Proposal for a regulationRecital 13

(13)In order to provide operators that are micro or small undertakings within the meaning of Article 3(1) or (2), first subparagraph, of Directive 2013/34/EU, with adequate time for the implementation of the proposed amendments, the corresponding dates of application of the provisions of Regulation (EU) 2023/1115 that lay down obligations on operators, traders and competent authorities, listed in Article 38(2) of that Regulation, should be set to 30 December 2026 for micro and small operators.

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Amendments 72 and 110Proposal for a regulationRecital 15

(15)Where a competent authority becomes or is made aware of non-compliance with Regulation (EU) 2023/1115 prior to the entry into application of Articles 16 to 19, Article 22 and Article 24, it may issue warnings to operators, downstream operators and traders, accompanied by recommendations to achieve compliance.

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Amendment 111Proposal for a regulationRecital 16

(16)In the light of the postponement of the date from which for micro and small operators are required to comply with Regulation (EU) 2023/1115, the dates in other related provisions, namely the repeal of Regulation (EU) No 995/2010 of the European Parliament and of the Council8, the transitional provisions and the provisions on the deferred application of Regulation (EU) 2023/1115 to micro-undertakings or small undertakings, should be adjusted accordingly. In order to provide sufficient time to align technical developments of the electronic interface based on the European Union Single Window Environment for Customs, the date by which the electronic interface is in place should be adjusted accordingly.

(16)In the light of the postponement by 12 month of the date of application set out in Article 38(2) of Regulation (EU) 2023/1115, the dates in other related provisions, namely the repeal of Regulation (EU) No 995/2010 of the European Parliament and of the Council, the provisions on the deferred application of Regulation (EU) 2023/1115 to natural persons, micro-undertakings or small undertakings, should be adjusted accordingly. In order to provide sufficient time to align technical developments of the electronic interface based on the European Union Single Window Environment for Customs, the date by which the electronic interface is in place should be adjusted accordingly.

Amendment 112Proposal for a regulationRecital 20 (new)

(20)In view of the urgency to adopt targeted simplifications as well as to delay the entry into application of Regulation (EU) 2023/1115, it is considered to be appropriate to invoke the exception to the eight-week period provided for in Article 4 of Protocol No 1 on the role of national Parliaments in the European Union, annexed to the Treaty on European Union, to the Treaty on the Functioning of the European Union and to the Treaty establishing the European Atomic Energy Community.

Amendment 113Proposal for a regulationArticle 1 – point 1 – point bRegulation (EU) 2023/1115Article 2 – point 15a

(15a)‘micro and small primary operator’ means an operator who is a natural person or a micro- or small-sized undertaking, as defined in Article 3(1) and (2), first subparagraph, of Directive 2013/34/EU of the European Parliament and of the Council*, irrespective of its legal form, established in a country classified as low risk in accordance with Article 29 of this Regulation, and who, in the course of a commercial activity, places on the market or exports relevant products that this operator itself has grown, harvested, obtained from or raised on relevant plots of land, or, as regards cattle, on establishments;

(15a)‘micro and small primary operator’ means an operator who is a natural person or a micro- or small-sized undertaking, as defined in Article 3(1) and (2), first subparagraph, of Directive 2013/34/EU of the European Parliament and of the Council*, irrespective of its legal form, established in a country classified as low risk in accordance with Article 29 of this Regulation, and who, in the course of a commercial activity, places on the market or exports relevant products that this operator itself has grown, harvested, obtained from or raised on relevant plots of land, or, as regards cattle, on establishments, located in that country; this includes operators who exceed the limits of at least two of the three criteria set out in Article 3(1) and (2), first subparagraph, of Directive 2013/34/EU but who can demonstrate that the parts of their balance sheet total, net turnover and average number of employees during the financial year which relate to their activities covered by this Regulation do not exceed the limits of at least two of three of those criteria;

Amendments 74 and 114Proposal for a regulationArticle 1 – point 5Regulation (EU) 2023/1115Article 4a – paragraph 1

1.The obligations laid down in Article 4(2), (3) and (4), point (c) shall not apply to micro and small primary operators.

1.The obligations laid down in Article 4(2), the second sentence of Article 4(3) and Article 4(4), point (c) shall not apply to micro and small primary operators.

Amendments 75 and 115Proposal for a regulationArticle 1 – point 5Regulation (EU) 2023/1115Article 4a – paragraph 2

2.Micro and small primary operators shall submit a one-time simplified declaration in the information system referred to in Article 33 before placing on the market relevant products or exporting them. They shall be assigned a declaration identifier after submitting their simplified.

2.Micro and small primary operators shall submit a one-time simplified declaration in the information system referred to in Article 33 before placing on the market relevant products or exporting them. They shall be assigned a declaration identifier after submitting their one-time simplified declaration.

Amendment 116Proposal for a regulationArticle 1 – point 5Regulation (EU) 2023/1115Article 4a – paragraph 3

3.Micro and small primary operators shall provide the information set out in Annex III when submitting the simplified declaration in the information system. They shall update the information contained in their simplified declaration following any changes to the information they provided. 

3.Micro and small primary operators shall provide the information set out in Annex III when submitting the simplified declaration in the information system. They may update the information contained in their simplified declaration following any major changes to the information they provided. 

Amendments 77 and 117Proposal for a regulationArticle 1 – point 5Regulation (EU) 2023/1115Article 4a – paragraph 4

4.Where all information listed in Annex III is available in a system or database that exists under Union or Member States legislation, other than the information system referred to in Article 33, micro and small primary operators shall not be required to submit a simplified declaration in accordance with paragraph 2 of this Article. Member States shall make this information per operator available in the information system referred to in Article 33. The micro or small primary operator shall place the relevant products on the Union market or export them only after having been assigned a declaration identifier.

4.Where all information listed in Annex III is available in a system or database that exists under Union or Member States legislation, other than the information system referred to in Article 33, micro and small primary operators shall not be required to submit a one-time simplified declaration in accordance with paragraph 2 of this Article. Member States shall make this information per operator available in the information system referred to in Article 33. The micro or small primary operator shall place the relevant products on the Union market or export them only after having been assigned a declaration identifier.

Amendments 78 and 118Proposal for a regulationArticle 1 – point 5Regulation (EU) 2023/1115Article 4a – paragraph 5

5.For micro and small primary operators, the geolocation referred to in Article 9(1), point (d), may be replaced by the postal address of all plots of where the relevant commodities that the relevant product contains, or has been made using, were produced.’;

5.For micro and small primary operators, the geolocation referred to in Article 9(1), point (d), may be replaced by the postal address of all plots of land or the postal address of the establishment from where the relevant commodities that the relevant product contains, or has been made using, were produced.’;

Amendments 79 and 119Proposal for a regulationArticle 1 – point 6Regulation (EU) 2023/1115Article 5 – paragraph 1

1.Downstream operators and traders shall make available relevant products on the market only if they are in possession of the information required under paragraph 3.

1.Downstream operators and traders shall place or make available relevant products on the market or export them only if they are in possession of the information required under paragraph 3.;

Amendments 50, 80 and 120Proposal for a regulationArticle 1 – point 6Regulation (EU) 2023/1115Article 5 – paragraph 3 – point a

(a)the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the operators, downstream operators, or the traders who have supplied the relevant products to them, as well as the reference numbers of the due diligence statements or the declaration identifiers associated to those products;

(a)the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the operators, downstream operators, or the traders who have supplied the relevant products to them, as well as the reference numbers of the due diligence statements or the declaration identifiers associated to those products only in case their supplier is an operator;

Amendments 34, 49, 81 and 121Proposal for a regulationArticle 1 – point 6Regulation (EU) 2023/1115Article 5 – paragraph 5

5.Downstream operators and traders shall communicate to downstream operators and traders to whom they have supplied relevant products the reference numbers of the due diligence statements or the declaration identifiers associated to those relevant products.

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Amendments 82 and 122Proposal for a regulationArticle 1 – point 16 – point aRegulation (EU) 2023/1115Article 26 – paragraph 4

4.The reference number of the due diligence statement or the declaration identifier for micro and small primary operators shall be made available to customs authorities before the release for free circulation or export of a relevant product entering or leaving the market. For that purpose, except where the due diligence statement is made available through the electronic interface referred to in Article 28(2), the person lodging the customs declaration for release for free circulation or export of a relevant product shall make available to customs authorities the reference number of the due diligence statement or the declaration identifier for micro and small primary operators associated to that relevant product.

4.The reference number of the due diligence statement or the declaration identifier for micro and small primary operators shall be made available to customs authorities before the release for free circulation or export of a relevant product entering or leaving the market. For that purpose, except where the due diligence statement is made available through the electronic interface referred to in Article 28(2), the person lodging the customs declaration for release for free circulation or export of a relevant product shall make available to customs authorities the reference number of the due diligence statement or the declaration identifier for micro and small primary operators associated to that relevant product. This paragraph shall not apply to the export of a relevant product by a downstream operator.

Amendments 62 and 123Proposal for a regulationArticle 1 – point 21Regulation (EU) 2023/1115Article 34 – paragraph 1 a (new)

1a.By 30 April 2026, the Commission shall carry out a simplification review of this Regulation and on this basis present a report to the European Parliament and the Council accompanied, where appropriate, by a legislative proposal.

Amendment 48Proposal for a regulationArticle 1 – point 21Regulation (EU) 2023/1115Article 34 – paragraph 2 a (new)

2a.The Commission shall establish a permanent stakeholder group and shall ensure continued exchange with experts, stakeholders and operators to develop best practices and collect technical feedback after the entry into application of the Regulation.

Amendments 55 and 124Proposal for a regulationArticle 1 – point 22Regulation (EU) 2023/1115Article 37 – paragraph 1

1.Regulation (EU) No 995/2010 is repealed with effect from 30 December 2025.

1.Regulation (EU) No 995/2010 is repealed with effect from 30 December 2026.

Amendment 126Proposal for a regulationArticle 1 – point 22Regulation (EU) 2023/1115Article 37 – paragraph 2

2.Regulation (EU) No 995/2010 shall continue to apply:

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(a)until 30 December 2026 to timber and timber products as defined in Article 2, point (a), of Regulation (EU) No 995/2010 placed on the market by micro and small primary operators or by operators that by 31 December 2024 were established as micro-undertakings or small undertakings, within the meaning of Article 3(1) or (2), first subparagraph, of Directive 2013/34/EU, irrespective of their legal form;

(b)until 31 December 2028 to timber and timber products as defined in Article 2, point (a), of Regulation (EU) No 995/2010 that were produced before 29 June 2023 and placed on the market from 30 December 2026 by micro and small primary operators or by operators that by 31 December 2024 were established as micro-undertakings or small undertakings within the meaning of Article 3(1) or (2), first subparagraph, of Directive 2013/34/EU, irrespective of their legal form;

(c)until 31 December 2028 to timber and timber products as defined in Article 2, point (a), of Regulation (EU) No 995/2010 that were produced before 29 June 2023 and placed on the market from 30 December 2025.

Amendment 125Proposal for a regulationArticle 1 – point 22Regulation (EU) 2023/1115Article 37 – paragraph 2 a (new)

2a.However, Regulation (EU) No 995/2010 shall continue to apply until 31 December 2029 to timber and timber products as defined in Article 2, point (a), of Regulation (EU) No 995/2010 that were produced before 29 June 2023 and placed on the market from 30 December 2026.

Amendment 127Proposal for a regulationArticle 1 – point 22Regulation (EU) 2023/1115Article 37 – paragraph 3

3.By way of derogation from Article 1(2) of this Regulation, the timber and timber products as defined in Article 2, point (a), of Regulation (EU) No 995/2010 that were produced before 29 June 2023 and placed on the market from 31 December 2028 shall comply with Article 3 of this Regulation.’;

3.By way of derogation from Article 1(2) of this Regulation, the timber and timber products as defined in Article 2, point (a), of Regulation (EU) No 995/2010 that were produced before 29 June 2023 and placed on the market from 31 December 2029 shall comply with Article 3 of this Regulation.’;

Amendments 63 and 128Proposal for a regulationArticle 1 – point 23Regulation (EU) 2023/1115Article 38 – paragraph 2

2.Articles 3 to 13, Articles 20, 21, 23, 26, 31 and 32 shall apply from 30 December 2025.

2.Subject to paragraph 3 of this Article, Articles 3 to 13, Articles 16 to 24, Articles 26, 31 and 32 shall apply from 30 December 2026.

Amendment 53Proposal for a regulationArticle 1 – point 23Regulation (EU) 2023/1115Article 38 – paragraph 2 a (new)

2a. Competent authorities shall communicate to the Commission any documented difficulties, errors or disruptions arising from the Union information systems referred to in Article 33, to ensure that operators and traders subject to the grace period are not disadvantaged by such issues.

Amendments 64 and 129Proposal for a regulationArticle 1 – point 23Regulation (EU) 2023/1115Article 38 – paragraph 3

3. For operators that by 31 December 2024 were established as micro-undertakings or small undertakings within the meaning of Article 3(1) or (2), first subparagraph, of Directive 2013/34/EU, irrespective of their legal form, the Articles referred to in paragraph 2 of this Article shall apply from 30 December 2026.

3.Except as regards the products covered in the Annex to Regulation (EU) 995/2010, for operators, whether natural persons or micro- or small-sized undertakings as defined in Article 3(1) or (2) of Directive 2013/34/EU, who were established as such by 31 December 2024, the Articles referred to in paragraph 2 of this Article shall apply from 30 June 2027.

Amendments 27, 89 and 130Proposal for a regulationArticle 1 – point 23Regulation (EU) 2023/1115Article 38 – paragraph 4

4.For micro and small primary operators, the Articles referred to in paragraph 2 of this Article shall apply from 30 December 2026.

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Amendments 28, 90 and 131Proposal for a regulationArticle 1 – point 23Regulation (EU) 2023/1115Article 38 – paragraph 5

5.Articles 16 to 19, Articles 22 and Article 24 shall apply from 30 June 2026 with regard to measures concerning operators, downstream operators and traders, and from 30 December 2026 to operators referred in paragraphs 3 and 4. Where a competent authority becomes or is made aware of non-compliance with Regulation (EU) 2023/1115 prior to the entry into application of Articles 16 to 19, Article 22 and Article 24, it may issue warnings to operators, downstream operators and traders, accompanied by recommendations to achieve compliance.’

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Amendment 45Proposal for a regulationArticle 1 – point 23Regulation (EU) 2023/1115Article 38 – paragraph 5 a (new)

5a.Competent authorities shall take into account relevant information, including complaints, reports, and substantiated concerns, and shall, for the period preceding the dates referred to in Article 38 give due consideration to communications from the Commission concerning IT-related problems or inadvertent errors resulting therefrom, for the purposes of avoiding administrative sanctions on operators covered by Article 38 without prejudice to Article 25.

Amendment 65Proposal for a regulationArticle 1 – paragraph 1 – point 23 a (new)Regulation (EU) 2023/1115Annex I

(23a)in Annex I, products ex 49 are deleted;

Amendments 60, 91 and 132Proposal for a regulationAnnex IIRegulation (EU) 2023/1115Annex III – introductory part

Information to be contained in the simplified declaration of micro and small primary operators in accordance with Article 4a(3):

Information to be contained in the simplified one-time declaration of micro and small primary operators in accordance with Article 4a(3):

Amendments 92 and 133Proposal for a regulationAnnex IIRegulation (EU) 2023/1115Annex III – point 2

2.Harmonised System code and free-text description of the relevant products, including the trade name, and the annual quantity of relevant products intended to be placed on the market or exported, expressed in net mass specifying a percentage estimate or deviation or, where applicable, volume or number of items. For relevant products entering or leaving the market, the quantity is to be expressed in kilograms of net mass and, where applicable, in the supplementary unit set out in Annex I to Regulation (EEC) No 2658/87 against the indicated Harmonised System code or, in all other cases, expressed in net mass specifying a percentage estimate or deviation or, where applicable, volume or number of items. A supplementary unit is applicable where it is defined consistently for all possible subheadings under the Harmonised System code referred to in the due diligence statement.

2.Harmonised System code and free-text description of the relevant products, including the trade name, and the one-off estimated annual quantity of relevant products intended to be placed on the market or exported, expressed in net mass specifying a percentage estimate or deviation or, where applicable, volume or number of items. For relevant products entering or leaving the market, the estimated quantity is to be expressed in kilograms of net mass and, where applicable, in the supplementary unit set out in Annex I to Regulation (EEC) No 2658/87 against the indicated Harmonised System code or, in all other cases, expressed in net mass specifying a percentage estimate or deviation or, where applicable, volume or number of items. A supplementary unit is applicable where it is defined consistently for all possible subheadings under the Harmonised System code referred to in the due diligence statement.

Amendments 93 and 134Proposal for a regulationAnnex IIRegulation (EU) 2023/1115Annex III – point 3

3.Country of production and the postal address or the geolocation of all plots of land on which the micro and small primary operator produces relevant commodities. For relevant products that contain or have been made using cattle, and for such relevant products that have been fed with relevant products, the postal address or the geolocation shall refer to all the establishments where the cattle are kept. Where the relevant products are produced on different plots of land, the postal address or the geolocation of all plots of land shall be included in accordance with Article 9(1), point (d).

3.Country of production and the postal address or the geolocation of all plots of land, or the postal address of the establishment or of all plots of land on which the micro and small primary operator produces relevant commodities. For relevant products that contain or have been made using cattle, and for such relevant products that have been fed with relevant products, the postal address or the geolocation shall refer to all the establishments where the cattle are kept. Where the relevant products are produced on different plots of land, the postal address or the geolocation of all plots of land shall be included in accordance with Article 9(1), point (d).