EUDR FAQ – Answers to the Most Common Questions About the EU Deforestation Regulation and the Planned Delay

The EU Deforestation Regulation (EUDR) is currently one of the most discussed topics in supply chain management and sustainability. Following the European Commission’s latest announcement on October 21, many new questions have emerged—especially around the proposed EUDR delay and implications for so-called downstream operators and traders.

Based on our EUDR webinar with Dr. Andreas Thürauf (Attorney at Law at SKUSA Partners) and Jonas Gehrke (Sustainability Expert at IntegrityNext), we address the most common questions—from the fundamentals to the latest developments. Watch the full webinar recording here.

What is the EUDR?

The EU Deforestation Regulation (EUDR) requires companies to ensure that certain raw materials and products placed on the EU market do not originate from deforested or degraded land. Its goal is to reduce Europe’s contribution to global deforestation.

The EUDR replaces the previous EU Timber Regulation (EUTR) and applies to several key commodities and derived products, including:

• Wood
• Coffee
• Cocoa
• Soy
• Oil palm
• Cattle products
• Rubber

When Does the EUDR Come into Effect?

According to the latest proposal by the European Commission, the EUDR will apply to most companies starting December 30, 2025.

However, the proposal introduces two key adjustments:

• A six-month grace period until June 2026: During this time, no sanctions will be imposed, even though companies are already required to fulfill due diligence obligations.

• Small and micro enterprises will have until the end of December 2026 to fully implement their processes.

These changes are part of the Commission’s latest amendment proposal published on October 21, 2025, which still needs to be formally adopted by the European Parliament and the Council, likely before the end of the year.

Why Was the EUDR Delayed?

According to the European Commission, the main reason for the proposed EUDR delay is technical: the EU TRACES system, through which all due diligence statements must be submitted, is currently unable to process the expected volume of data.

As a result, the Commission has proposed to simplify or phase in the obligations for certain groups of companies to reduce the strain on the system.

From a legal standpoint, however, the core objective of the EUDR remains unchanged: only deforestation-free products may be placed on the EU market.

Who Is Affected by the EUDR?

The EUDR distinguishes between several types of market participants:

• Upstream Operators
  Companies that place products on the EU market for the first time—such as importers or manufacturers. They must prepare comprehensive Due Diligence Statements (DDS) and submit them through the TRACES system.
• Downstream Operators and Traders
  These are traders or processors who buy products that are already on the EU market. According to the Commission’s proposal, they will no longer need to submit their own DDS, but must collect and pass on the reference numbers of their suppliers’ due diligence statements.
• Small and Micro Enterprises
  These companies will only need to submit simplified, one-time declarations if they import from countries classified as having a low deforestation risk.

What Remains Unchanged Despite the EUDR Adjustments?

Even with the proposed simplifications, the core obligations under the EUDR remain in place:

• Data collection and documentation throughout the supply chain
• Sharing of information with customers and authorities
• Risk assessment and mitigation for relevant commodities and derived products
• Proof of deforestation-free origin
• Compliance with local laws

Companies should clearly define their role within the supply chain, identify which products are affected (see Annex I of the regulation), and establish processes and IT systems for data collection and documentation well in advance.

What Does the Six-Month Grace Period Mean?

The proposed grace period is intended to give companies time to fully implement their processes and systems before authorities begin active enforcement.

During this period:

• Due diligence obligations already apply,

• but no sanctions will be imposed.

In other words, companies must act in compliance with the law but can expect greater flexibility for adjustments during this transition phase.

Key EUDR Questions From Practitioners – Answers for Businesses

• Do traders really no longer need to submit a DDS?
  As things stand: No. Traders are classified as downstream operators and will only need to collect and forward their suppliers’ reference numbers. Whether this simplification will be implemented as proposed depends on the final decision.
• Does the grace period also apply to large companies?
  Yes. The proposal provides for a six-month grace period for all companies, regardless of their size.
• How should companies handle composite products?
  For EUDR-relevant components (e.g., wood in furniture or cocoa in food products), reference numbers must be passed on even if the overall product is only partially covered.
• What happens if a supplier fails to comply?
  Even if traders are not required to submit their own DDS, they remain responsible if there are substantiated concerns about the accuracy of their suppliers’ information.
• When can we expect the final version of the EUDR?
  Experts anticipate that the final version will be adopted by the end of the year, as the European Commission is exerting strong pressure on both the Parliament and the Council to conclude the process swiftly.

Conclusion: Preparation Is Key

Even with the slight delay and the distinction between affected actors, compliance obligations remain in full effect.

Companies should now:

• Clearly define their role in the value chain and affected products
• Proactively implement due diligence measures
• Prepare IT systems and supplier communication processes
• Strengthen internal knowledge through training and external expertise
• Those who act early minimize risks and will be well prepared—regardless of when the EUDR officially takes effect.

This article is based on the IntegrityNext webinar “EUDR – Frequently Asked Questions”.