• Blog
  • EUDR Delay 2025/2026: What it Means for Supply Chains and Procurement (Updated January 13, 2026)
January 13, 2026
Max Gruber
Connect on

EUDR Delay 2025/2026: What it Means for Supply Chains and Procurement

Updated January 13, 2026
With the EUDR delay and amendments now confirmed, key application deadlines will be postponed. The revised timeline is designed to ease the burden on downstream operators and simplify requirements for small and micro-enterprises while keeping core due diligence rules firmly in place. This article outlines how these changes will affect supply chains and procurement planning.

EUDR Delay – A Brief Overview

On December 17, 2025, the European Parliament adopted targeted amendments to the EU Deforestation Regulation (EUDR) aimed at supporting a more practical implementation process. The decision confirms a one-year postponement of the main application dates and introduces specific simplifications to due diligence obligations, with a particular focus on downstream operators, small and micro primary operators.

The amendments took effect on December 23, 2025, after publication in the Official Journal of the EU. Looking ahead, further adjustments remain possible. A simplification review clause requires the European Commission to present an assessment report by April 30, 2026, which may be accompanied by another legislative proposal.

The extended timeline gives companies a critical opportunity to prepare. They should use this time to:

  • Establish stable internal processes
  • Set up or refine traceability and documentation systems
  • Assign clear responsibilities for EUDR compliance

Robust data, transparency, and documentation along the supply chain remain essential pillars of due diligence. Meeting these requirements will take time, planning, and collaboration across functional units and stakeholder groups.

Now is the time to assess readiness, clean up internal data, engage with suppliers, and invest in systems that will ensure compliance in line with the new deadlines.

Key takeaways for EUDR Delay Note: Information as of January 13, 2026.

What Are the Changes Introduced by the Amended EUDR Regulation?

The amended EUDR Regulation confirms a one-year postponement of the main application dates, introduces selected simplifications to due diligence obligations, and narrows the product scope in certain areas – while maintaining the law's core objective: to achieve deforestation-free supply chains.

The following changes are key:

  • One-year delay for all operators and traders, compared to the previous EUDR timeline.
  • Mandatory Commission review to finalize the central IT system, issue guidance documents and delegated acts, and propose additional legislative adjustments if needed.
  • Simplified due diligence obligations for downstream operators and traders, and for a new category of small and micro primary operators in low-risk countries.
  • Removal of printed products (HS Code “ex 49”) from the regulation’s scope, based on the customs classifications listed in Annex I of the EUDR.

Looking ahead, companies should continue to closely monitor further regulatory developments and national implementation.

How Does the Updated EUDR Timeline Vary by Company Size? 

A key change in the revised EUDR is a universal one-year postponement of the main application deadlines. The updated compliance dates are as follows:

  • December 30, 2026 – for large and medium-sized enterprises
  • June 30, 2027 – for small and micro-enterprises

Adapted EUDR Timeline as of December 17, 2025Note: Information as of January 13, 2026.

The timeline applies the EU’s standard enterprise size definitions:

  • Large enterprises are undertakings that meet at least two of the following criteria: more than 250 employees, annual net turnover above €50 million, total balance sheet above €25 million
  • Micro, small and medium enterprises that meet at least two of the following criteria: less than 250 employees, annual net turnover below €50 million, total balance sheet below €25 million
  • Micro and small enterprises are a subset of companies that meet at least two of the following criteria: 50 or fewer employees, annual net turnover of €15 million, total balance sheet of €7.5 million. For the newly defined category of micro and small “primary operators”, the EUDR amendment clarifies which business activities count toward these thresholds, and which may be excluded.

This classification matters in two ways. First, it determines when the EUDR obligations take effect and, second, it influences the level of due diligence required. Micro and small primary operators located in low-risk countries will be subject to simplified obligations and no longer need to ensure the continuous submission of due diligence statements (DDS).

In practice, this means that larger operators should treat 2026 as a critical period for implementation, while micro and small companies should use the additional time to prepare their data, processes, and IT systems.

What does the EUDR Amendment Mean for Operators, Downstream Operators, and Traders?

The recent amendments to the EUDR do not fundamentally change who holds core compliance responsibilities, but they refine timelines and simplify obligations for some actors, particularly smaller entities and those in low-risk regions.

Implications for Operators:

Operators remain the primary entities responsible for compliance under the EUDR. Their responsibilities are largely unchanged.

  • With the exception of micro and small primary operators, all operators must continue to perform full due diligence and submit Due Diligence Statements (DDS) in the EU information system for any relevant products they place on the EU market or export from the EU.
  • Traceability obligations – including the collection of geolocation data, risk assessments, and mitigation measures – remain fully in place.
  • The delayed application date offers additional time to establish due diligence systems, finalize data collection, build internal processes, and test IT integrations before enforcement begins.

Implications for Downstream Operators and Traders:

While core due diligence remains with operators, the administrative burden on downstream operators and traders is adjusted under the new rules.

  • Downstream operators and traders are no longer required to submit their own DDS – this responsibility remains with the operator.
  • Non-SME downstream operators and traders must register in the EU information system. Only first-tier entities (i.e., those buying directly from operators) are required to collect and store DDS reference numbers or declaration identifiers for products purchased from operators and maintain relevant documentation for national competent authorities.
  • In the event of substantiated concerns, all downstream operators and traders must notify authorities and affected customers. Additionally, non-SME downstream operators and traders must verify that due diligence was exercised and that only negligible risk remains before placing or trading products on the EU market. They must also document the outcome of this verification. 

Implications for Micro and Small Primary Operators:

 These operators benefit from a simplified approach when sourcing from low-risk countries but still retain key responsibilities.

  • Instead of submitting a DDS for each product, they may provide a one-time declaration, as long as products originate from low-risk countries.
  • They remain responsible for ensuring the accuracy of producer and plot data (and further information outlined in Annex III) and must update their declarations when significant changes occur.
  • Larger downstream buyers will continue to rely on timely and reliable data from these operators, making capacity-building and support initiatives along the supply chain critical for overall compliance.

What Other Changes Does the EUDR Amendment Introduce?

Beyond the revised timeline and due diligence simplifications, the EUDR amendment introduces several targeted changes to the regulation’s structure and implementation framework.

One key change is the removal of printed products falling under HS code “ex” 49 in Annex I. This effectively exempts most books and printed materials, addressing concerns from the publishing sector about the proportionality and feasibility of full EUDR compliance.

The amendment also strengthens IT system oversight. National competent authorities are now required to report significant technical errors or disruptions in the EU information system to the European Commission. This measure aims to enhance transparency and enable coordinated responses to system-wide issues.

Additionally, the amendment reaffirms the importance of ongoing stakeholder engagement and dialogue. While the Commission’s expert group and multi-stakeholder platform do not hold formal decision-making power, their technical input will continue to inform EUDR implementation and potential future revisions – including the 2026 simplification review.

These changes do not alter the core obligation to ensure deforestation-free sourcing. However, they refine how the regulation will operate in practice and clarify how businesses should interact with national competent authorities as compliance processes evolve.

Turning the EUDR Delay into a Strategic Advantage

The EUDR amendment does not signal a change in regulatory direction. It provides a clearer and more realistic compliance path, with simplified obligations and extended timelines. However, the postponement should not be seen as a reason to delay action.

The core obligations of the EUDR remain intact, and national authorities are expected to begin checks from the revised application dates. Designing due diligence processes, collecting geolocation data, aligning with suppliers, and ensuring traceability requires significant effort.

Now is the time to take advantage of the additional preparation period – before last-minute bottlenecks arise. Companies that act early will not only reduce compliance risks but also demonstrate leadership in deforestation-free sourcing. This proactive approach supports cost efficiency over time and protects brand reputation.

Tools like the IntegrityNext EUDR Solution ensure targeted, effective implementation and help teams build readiness well before deadlines arrive.

How IntegrityNext Supports EUDR Compliance Under the New Rules

IntegrityNext supports EUDR compliance under the new framework by providing a centralized workspace to collect, store, and manage supplier and product data, including Due Diligence Statements (DDS). This enables operators and first-tier downstream actors to link inbound and outbound transactions for full traceability and to efficiently manage DDS reference numbers – even when only a single statement is submitted at market entry.

The platform also ensures extensive documentation for audits and regulatory checks, and leverages risk assessment tools to help verify suppliers when substantiated concerns arise.

Because IntegrityNext can be deployed immediately, companies can begin onboarding suppliers quickly, integrate the platform with internal systems in a controlled environment, and prepare well in advance of EUDR enforcement deadlines.

Frequently Asked Questions (FAQ): EUDR Delay 2025/2026

1. Has the EUDR delay already been formally adopted?

Yes, the amendment took effect on December 23, 2025, following publication in the Official Journal of the EU.

2. From when does the EUDR apply to large and medium enterprises?

The main EUDR obligations will apply to large and medium-sized enterprises starting on December 30, 2026. The additional year is intended to support implementation but does not change the substance of the due diligence requirements.

3. What are the main changes to EUDR due diligence obligations?

In the amended framework, only operators who place products on the EU market or export them from the EU must submit a due diligence statement (DDS). Non-SME downstream operators and traders must register in the EU information system, and first-tier downstream operators and traders, i.e. actors purchasing directly from operators, must collect DDS reference numbers and retain supporting documentation, but they no longer need to submit their own DDS. Micro and small primary operators in low-risk countries can submit a simplified, one-time declaration instead of repeated DDS submissions.

4. Does the delay mean companies can pause EUDR projects?

No. The delay offers greater certainty, not a reason to pause. Designing compliance processes, collecting geolocation data, onboarding suppliers, and testing systems requires time. Companies that delay these activities risk last-minute bottlenecks, higher costs, and a greater risk of non-compliance once checks begin.

5. How does IntegrityNext support EUDR compliance under the new rules?

IntegrityNext provides a central platform to collect, store, and manage supplier and product data—including due diligence statements and identifiers. The system links inbound and outbound transactions for full traceability, ensures documentation for authority checks, and leverages risk assessment tools to help companies respond to concerns. This allows businesses to use the extended timeline to build a stable, scalable EUDR compliance framework before enforcement begins.

6. Are downstream operators and traders now exempt from EUDR obligations?

No. Their responsibilities have been simplified, not removed. They must still ensure that all products are covered by a valid DDS or declaration, retain documentation, and respond appropriately if substantiated concerns are raised by authorities or other stakeholders.

Go back