EUDR Delay 2025/2026: What Really Applies (and What’s Still Under Discussion)

EUDR Delayed? – The Overview

On October 21, 2025, the European Commission published a proposal to simplify the implementation of the EU Deforestation Regulation (EUDR) and make the transition smoother for companies. The proposal suggests postponing the application date for micro and smaller businesses and easing due diligence obligations as well as the requirement to submit due diligence statements (DDS) for downstream operators and traders.

Nothing has been decided yet — the European Parliament and the Council still need to approve the proposal. Nonetheless, the direction is clear: pragmatism over perfection.

Reconciling Ambition and Practical Implementation

The EUDR is one of the EU’s most ambitious sustainability initiatives. It requires companies to ensure that their products are not linked to deforestation — covering commodities such as soy, palm oil, coffee, cocoa, timber, and more.

However, implementation has presented practical challenges for many stakeholders: complex data requirements, IT systems still under development, and suppliers outside the EU with limited resources.

With its new proposal, the European Commission aims to ease the burden on companies without lowering the level of ambition. As Environment Commissioner Jessika Roswall put it: “This is not about lowering ambition — it’s about making the rules work better and smarter.”

Commission Update: Delay Only for Micro and Small Enterprises + Relief for Downstream Operators and Traders

According to the European Commission’s press release published on October 21, 2025, the proposal includes three main measures:

Relief for Downstream Operators and Traders

Large traders and processing companies (e.g., retailers, food companies, and furniture manufacturers) that purchase EUDR-relevant products within the EU would no longer be required to submit their own due diligence statements (DDS).

Instead, a single DDS – submitted by the operator placing the product on the EU market for the first time – would apply across the entire supply chain. Downstream operators and traders would only need to pass on existing DDS reference numbers along the chain. If there are justified concerns about EUDR compliance, certain obligations would still apply.

Example: For imported cocoa beans, the importer’s DDS would be sufficient. A chocolate manufacturer would not need to file a new declaration but must obtain the supplier’s DDS reference number, store it internally, and forward it to customers as required.

Simplifications for Micro and Small Enterprises

Companies falling into this category would only be required to comply with the EUDR from December 30, 2026.

For so-called primary operators producing EUDR-relevant goods in low-risk countries (according to the EU’s country benchmarking), a single simplified DDS in the EU information system would be sufficient, replacing regular submissions.

If relevant data already exists in national databases, no additional data input into the EU system would be necessary.

Transition Periods for Larger Companies

Large and medium-sized enterprises remain on schedule for December 30, 2025, but would benefit from a six-month enforcement grace period to allow for a phased implementation.

Our Perspective: Simplification – Yes, But Stay on Schedule

We welcome the proposed simplifications, especially the relief for downstream operators as well as small and micro-enterprises. These measures make the EUDR more practical to implement and reduce unnecessary administrative burdens. What matters most is that companies can fulfil their documentation obligations easily – through clear data structures, automated processes, and practical IT integrations.

At the same time, it is crucial that the timeline remains in place. Only if the EUDR is implemented as planned can it truly contribute to protecting forests worldwide. Any further delay would postpone the urgently needed shift toward deforestation-free supply chains – and risk undermining the goal of reducing climate risks and biodiversity loss.

Why Act Now – Despite the Uncertainty

Even though the political decision is still pending, waiting is not an option. Companies that start implementing the EUDR now gain clear advantages:

• Avoid bottlenecks: Early supplier engagement prevents a last-minute data scramble before the deadline

• Improve cost efficiency: Spread the effort over several months instead of relying on ad-hoc projects at the last minute

• Ensure technical robustness: Allow time for testing, system integration, and audits – without panic

• Build reputational strength: Acting proactively demonstrates leadership and ESG commitment

• Stay flexible: Well-structured processes can be easily adapted if timelines change

Conclusion: Simplify, But Don’t Delay

The potential EUDR delay is not a step backward – it’s an opportunity to make implementation more practical. But the transition should not drag on forever. What matters now is action: collecting data, setting up processes, and testing systems. Those who start today won’t be caught off guard tomorrow.

The EUDR remains a milestone toward deforestation-free supply chains – and companies that prepare now will stand out as leaders, not followers.

FAQ on the EUDR Delay

Has the EUDR been postponed?

Not yet. The proposed changes still need to be approved by the European Parliament and the Council. Until then, the original implementation dates remain in force: December 30, 2025, for large and medium-sized companies, and June 30, 2026, for small and micro-enterprises.

Does my company need to submit a Due Diligence Statement (DDS)?

Yes — if you are an operator placing products on the EU market for the first time. Under the proposal, downstream operators and traders would be exempt from submitting their own DDS.

Which obligations remain in place?

The core EUDR requirements - traceability, geolocation, risk assessment, and documentation - remain mandatory for upstream operators, regardless of any delay or extended transition period.

What happens if the proposal is not approved?

If the new proposal is not adopted, the EUDR will take effect as originally planned on December 30, 2025.

Further Information on the EUDR Delay

• Commission proposes targeted measures to ensure the timely implementation of EU Deforestation Regulation (ec.europa.eu)
• EU Commission holds the line on deforestation regulation start date but new loopholes are opened (eia-international.org)
• EU to water down climate rules ahead of leaders’ summit (ft.com)
• Nestlé, Mars, Other Companies Warn Against Another Delay to EU’s Supply Chain Deforestation Law (esgtoday.com)