The story of the EU Deforestation Regulation (EUDR) had already taken many a twist and turn, but in the past couple of months it became even more of a saga. First, in September, the European Commission (EC) proposed pushing back implementation another year to the end of 2026. A month later, following much lobbying for and against the delay from business, MEPs, trade and industry and NGOs, came the latest EC proposal to put it back on track for introduction for most business on December 30, 2025. It wasn’t quite a volte face, however, as, among other things, it is now also proposed the regulation is simplified, compliance obligations won’t apply as far down the supply chain, and a grace period will follow introduction.
To recap, the EUDR forms one of the pillars of the EU Green Deal, the aim of which is to see the EU become a sustainable, circular bioeconomy, plus a net-zero one by 2050.
The goal of the EUDR itself is to end EU “imported deforestation”, that is deforestation and forest degradation resulting from its trade in so-called FERCS, Forest and Ecosystem Risk Commodities. One of these is timber, of course, with the regulation effectively replacing the EU Timber Regulation in terms of the due diligence obligations imposed on businesses placing timber and wood products on the EU market.
The other commodities in scope are soya, palm oil, cocoa, rubber, cattle/beef and coffee.
The EUDR stipulates businesses placing these products on the market (and that includes goods originating in the EU as well as imported) and also exporting them from the EU must undertake due diligence to ensure they are not implicated in deforestation or forest degradation. They must also be legally harvested in the country of origin and companies must provide geolocation coordinates for their provenance.
Supplier countries have also been benchmarked low, medium and high in terms of risk of deforestation, with due diligence obligations on companies placing their commodities on or exporting them from the EU market varying accordingly.
As the original implementation date of December 2024 approached, calls for a push-back grew, with affected trade sectors protesting that they did not have enough time to adapt to the EUDR’s demanding obligations. Finally, in October, the EU conceded, pushing back the introduction to December 2025 for large and medium businesses, June 2026 for small and microoperations.
This further 12 months was not only for business to prepare, but also to ensure the authorities across the EU were ready to enforce and administer the system. A critical factor in this was that the ‘Traces NT’ IT platform, to which businesses will upload EUDR due diligence statements, should also be fully tested, up and running, with companies given time to pilot it.
It was the IT system, and the conclusion it would not cope with the volume of data headed its way that led to the September 23, 2025, proposal from the EC to delay introduction another 12 months.
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