EUDR – for Publishers

New EUDR Proposal Announced at the Last Minute!

Updated 30 October 2025

On Tuesday, 21 October 2025, the EU Commission presented new proposals to amend the EUDR legislation.
The proposal includes both relaxations and partial postponements of the current requirements.
The proposal has not yet been adopted, but the key changes are as follows:

Key Changes in the Commission’s Proposal

• Only one due diligence statement must be submitted in TRACES.
  This must be done by the operator who first places the product on the EU market.
  Operators and traders further down the supply chain will not need to submit their own statements.

• Traders and downstream operators will only need to register in TRACES in order to share information such as
  contact details, operator name, and reference numbers – but they will not be required to verify the reference numbers.

• Small and micro enterprises will receive a six-month extension – new deadline: 30 December 2026.

• Small and micro enterprises will be exempt from due diligence and will instead submit a simplified conformity declaration.

• Medium and large enterprises must still comply with EUDR from 30 December 2025.

• Authority control and enforcement are proposed to be postponed by six months – to 30 June 2026.

Source: Danish Chamber of Commerce (Dansk Erhverv)

What Does This Mean for DBK?

The proposal fundamentally changes the assumptions underlying DBK’s development work on EUDR support. DBK is therefore reassessing the industry’s needs and evaluating the consequences for our planned solutions.

We are in close dialogue with the publishers’ reference group and the Danish Chamber of Commerce and will announce as soon as possible how DBK will meet the new requirements if the proposal is adopted.

Two Possible Scenarios

Plan A – Current Approach (Before the Commission’s Proposal)

• All large operators – including downstream ones – must perform their own due diligence and create their own trace numbers.

• DBK must support full warehouse management and a 100% match between physical inventory and EUDR data.

• This requires the development of a WMS system and integration with EUDR.

• Large retailers must document received inventory and perform their own due diligence/create their own trace numbers in the EU database.

• Compliance depends on alignment between physical picking and digital EUDR data.

• In this scenario, DBK is subject to significant system changes.

Plan B – From Warehouse Management to Data Flow (If the Amendment Proposal Is Adopted)

If the Commission’s amendment proposal is adopted, DBK’s role and technical focus will change significantly:

• Only the first operator (the one who introduces the product to the market) performs due diligence.
  Subsequent actors must simply be able to present reference numbers upon request.

• DBK’s role will be to ensure an efficient and transparent data flow of EUDR references –
  not warehouse management.
  → This means that WMS development will not be necessary.

• The focus shifts to making all relevant trace numbers available through:

  • Invoice

  • Data records

  • Shipping notice

  • MitDBK

• Retailers must store and be able to identify EUDR references linked to ISBNs via DBK’s data.

• Compliance is ensured through documentation and transmission of relevant trace numbers.

Delivery of EUDR Data to DBK

Printers and publishers must, as of 1 January 2026, provide EUDR data to DBK via product notifications.
The method of delivering EUDR data to DBK is independent of the two possible scenarios!

There are two ways to notify incoming goods to DBK:

• Via Mit DBK

  • The notification template will be expanded to include EUDR data.

• Via digital notification (for integration customers/integration printers)

  • The documentation for digital notification will be updated to allow submission of the required EUDR data.

Data Requirements

Since the Commission’s proposal has not yet been adopted by Parliament and the Council, DBK cannot yet define the final data set.

We are currently working from two possible directions:

What Happens Next?

DBK is closely monitoring developments and will adjust the solution in line with EU decisions.
We will continuously update this page as the reporting requirements are finalized.