EU Postpones Deforestation-Free Regulation Implementation Again

Latest EUDR delay gives all operators until December 2026 for compliance, with additional time for smaller companies

In December, for a second time, the European Parliament approved postponing the implementation of the European Union Deforestation-Free Products Regulation (EU) 2023/1115 (EUDR) by one year. The EUDR requires companies selling or exporting select commodities (cattle, wood, cocoa, soy, palm oil, coffee, and rubber) or derived products to demonstrate that their products do not contribute to agricultural-related deforestation or forest degradation.

Originally intended to go into effect Dec. 30, 2024, the EUDR was first postponed until Dec. 31, 2025. With this latest delay, large operators and traders will now have until Dec. 30, 2026 to comply, and smaller operators will have until June 30, 2027. 

EUDR "Simplification Review"

Along with these changes, the European Commission is expected to conduct a "simplification review" of the EUDR by April 30, 2026. The Commission must review the administrative burden operators, especially smaller ones, must shoulder to comply with the EUDR. If needed, the Commission must also submit a "legislative proposal" to address those burdens. 

Other changes to the regulation will include the removal of printed media (e.g., books and newspapers) from the EUDR, and downstream operators and traders will no longer be required to submit due diligence statements. Micro and small operators will be able to submit simplified declarations and use postal addresses instead of geolocation information in their declarations.

Different impacts on different sized operators

While the delay is granted to all operators and traders, the revisions appear to focus primarily on micro-, small-, and medium-sized companies. Large downstream operators are still required to register with the EUDR information system by the new deadline of Dec. 30, 2026, even though they will not be required to submit due diligence statements. Large companies that place an EUDR product or commodity on the EU market now have another year to confirm that their supply chains comply with the EUDR, although compliance requirements may change after the Commission's simplification review is completed. 

As the EUDR continues to evolve, large operators preparing for the impending regulatory requirements will be well-served to meet deadlines and avoid delays that could impact sales or result in fines.