The EU published amendments to the EU Deforestation Regulation on 19 December 2025 through Regulation (EU) 2025/2650. These amendments adjust operator obligations and modify how due diligence information flows through the supply chain.
EUDR amendments published - new downstream operator role and extended deadline
Furthermore, The European Commission has notified that access to TRACES will be temporarily restricted from 16 February until mid‑April.
Key changes relevant to UPM Timber
1. Application deadline postponed
The EUDR’s application date for medium and large companies has been postponed by 12 months, moving from 30 December 2025 to 30 December 2026.
2. New “downstream operator” category
The amendment introduces a new category called downstream operator, clarifying who must submit and forward due diligence statements (DDS):
- The first operator placing a regulated product on the EU market must submit the DDS and obtain the reference number.
- This reference number must be passed on only to the first downstream operator.
- Downstream operators are not required to pass reference numbers further down the chain.
Impact on UPM Timber processes
- UPM Timber will stop sending EUDR reference numbers and verification numbers to customers as of 16th of February, due to a temporary access limitation to EU Traces system announced by the Commission.
- Due to the amended rules and the updated downstream‑operator responsibilities, combined with the temporary TRACES access limitation, we will no longer attach EUDR reference numbers or verification identifiers to invoices or other sales documents.
UPM Timber’s commitment to EUDR compliance
UPM Timber remains fully committed to ensuring compliance with the EUDR and maintaining transparent, deforestation‑free, legally compliant supply chains. We will continue to adapt our practices as the European Commission finalizes system updates and publishes the required simplification review by 30 April 2026.