EU member states are currently discussing yet another postponement of the date of application of the EU Deforestation Regulation (EU) 2023/1115 to avoid overburdening the IT Information System that is necessary to communicate compliance data. If adopted, the deadline to implement EUDR obligations will be 30 December 2026 for large enterprises and 30 June 2027 for small and medium enterprises.
Below is a breakdown of what the EUDR is, what’s expected in the new proposal for delay, and what actions H2 suggests to embrace EUDR’s impact.
What is EUDR?
The EUDR, entered into force on 29 June 2023, repealed the EU Timber Regulation (EUTR) to support broader EU policy goals under the European Green Deal and Sustainability agendas. It requires companies to meet due diligence requirements and ensure that their supply chains do not contribute to deforestation or forest degradation.
This regulation applies to “relevant commodities” and their “relevant products” listed in the Annex I of the EUDR, linked to deforestation risk:
- cattle (and derived products)
- cocoa
- coffee
- oil palm
- rubber (natural)
- soya
- wood
The relevant products and their HS codes are provided in the list of Annex I for detailed assessment.
Operators placing these goods on the EU market (or exporting from it) must carry out due diligence — showing the products are deforestation-free, produced in accordance with the laws of the producing country, and covered by a due diligence statement (DDS). Traders, other actors on the supply chain that are not Operators, must communicate and keep a chain of custody of the DDS. The objective is both environmental (protecting forests, biodiversity, and climate) and regulatory (ensuring supply chain transparency and accountability).
What could be expected with the Commission’s current proposal?
This proposal is a response to the broad stakeholder feedback requesting extra time to prepare for compliance and a more efficient and less burdensome process. The Commission proposed a series of amendments to:
- Ensure the EUDR IT system is fully operational and able to accommodate higher-than-expected system load
- Simplify reporting obligations, especially for small actors and downstream companies.
- Maintain strong due diligence and traceability safeguards while reducing unnecessary administrative burden.
The Commission believes that the proposed simplification will reduce the administrative burden by approximately 30% for companies.
The key changes stated in the proposal will reduce the burden of supply chain under the simplification initiatives
Downstream Operators (e.g., retailers, manufacturers)
- Would no longer be required to submit due diligence statements (DDS).
- Only one DDS would be required per supply chain, submitted by the upstream Operator at the entry point of the EU market.
- Example: Cocoa beans need a DDS from the importer; chocolate manufacturers no longer need to submit their own.
Micro and Small Primary Operators (from both EU and low-risk third countries)
- Replace repeated due diligence statements with a one-time simple declaration in the IT system.
- If information already exists in national databases, operators do not have to submit anything.
In December 2024, the EU agreed to delay the application to 30 December 2025 for large operators and 30 June 2026 for micro and small enterprises. The recent proposal, if adopted, will grant companies time to comply before application:
- Large & Medium-Sized Companies
- Application date remains 30 December 2025.
- Six-month grace period for checks and enforcement
- Micro & Small Enterprises
- New application date: 30 December 2026.
The Commission will also prepare a contingency plan if the proposed amendment is not adopted in time and the date of application remains 30 December 2025.
Latest update on 17 Nov 2025: the 12 November EU vote on extending a six-month enforcement grace period for medium and large firms failed to reach a majority, leaving the proposal undecided. If member states do not agree to a grace period by 15 December, the EUDR would take effect on 30 December 2025 for large and medium companies and on 30 June 2026 for micro and small enterprises. Some member states instead voted to delay enforcement of the EUDR altogether by another year, to December 2026 for medium and large firms and June 2027 for small and micro firms. Under this proposal, there would be no grace period for enforcing the regulation after starting in 2026.
H2 suggested actions to comply with EUDR
While there is uncertainty around EUDR, it is unlikely to be discontinued. While keeping a close eye on regulatory developments, H2 would recommend companies to take initial steps to verify obligations under the EUDR:
- SCOPE: Check if your products are in the scope of EUDR by matching the commodities and products in the list of Annex I.
- ROLE: Verify your role in the supply chain to determine whether you are an Operator or Trader in the supply chain.
- SIZE: Verify your company size based on the EU accounting standard – large Operators/Traders would have more obligations than the SME ones.
- DATA: Due Diligence Data – Ensure you have the necessary information to meet the Due Diligence System (DDS) requirements, including supply chain data and proof of compliance as the following:
- Operator/Trader Details (Name, EORI Nummer1…)
- Product information (trade name, scientific name, HS code2, quantity)
- Traceability data (country of production, geolocation (map drawing of the area or uploading geolocation .json file), supplier information)
- Declaration of compliance (a statement declaring the product poses no or negligible risk, and additional supporting document)
- Reference number (if referencing a previously submitted DDS)
How we can help:
- Analyze applicability of EUDR to your products and business
- Track regulatory development of EUDR and provide tailored impact assessment
- Support submission, communication and documentation of Due Diligence Statement (DDS)
Footnote:
- EORI: An EORI (Economic Operators Registration and Identification) number is a unique identifier for businesses and individuals involved in customs activities (import/export/transit) within the EU. Economic operators must communicate this number to the customs authorities of the Member States for customs operations
- HS Codes: HS (Harmonized System) codes are crucial numerical identifiers that determine if a traded product falls under the regulation’s scope, linking specific commodities (like cattle, coffee, palm oil, soy, rubber, timber, cocoa) and their derivatives to required due diligence for deforestation-free sourcing, with Annex I of the EUDR listing these codes (often 8-digit EU Combined Nomenclature codes) for customs and compliance.
Published November 19th, 2025
This article image was generated with the assistance of Artificial Intelligence.