One year into the current mandate, a number of sustainability legislations adopted in the previous term are being reassessed, delayed or simplified as part of a broader push to streamline EU rules and support their effective implementation. The EU Deforestation-free Products Regulation (EUDR) is a prime example of this trend, with adjustments to its application timeline and a targeted review of its provisions aimed at reducing implementation challenges for businesses.
Originally set to apply from December 2024, the EU Deforestation-free Products Regulation has since been postponed, with its main due diligence obligations now set to apply from 30 December 2026 rather than the previous date of 30 December 2025. In addition, this is accompanied by a targeted revision politically agreed by the European co-legislators. Together, these developments reflect growing concerns about administrative burden, legal clarity and the practical readiness of both public authorities and businesses.
For companies trading commodities linked to deforestation, this evolving policy landscape represents both a challenge and an opportunity. While the EUDR’s complexity highlights the difficulties of compliance, the revised timeline and targeted adjustments also give businesses more time to prepare and position themselves as frontrunners in sustainable and resilient supply chains.
In this article, Publyon explores what the EU Deforestation-free Products Regulation is, the latest political developments, and what EUDR means for operators and traders.
What is the EU Deforestation-free Products Regulation?
On 29 June 2023, the Regulation on deforestation-free products entered into force. The Regulation aims to control EU imports linked to deforestation, with the goal of minimising the impact of the EU economy on deforestation and forest degradation. In addition, the aim is to bring down greenhouse gas emissions and biodiversity loss.
The main driver of these processes is the expansion of agricultural land that is linked to the production of commodities such as cattle, wood, cocoa, soy, palm oil, coffee, rubber, and some of their derived products, including leather, chocolate, tyres, or furniture. The Regulation specifically addresses the commerce of such commodities and derived products, which will have to pass thorough due diligence checks before being placed in or exported from the European market.
What is the status of the EU Deforestation-free Products Regulation?
The EU Deforestation-free Products Regulation (EUDR) was originally set to apply from 30 December 2024. However, concerns raised by Member States, third countries and economic operators about implementation readiness led to a first formal postponement in December 2024, shifting the application date to 30 December 2025.
As implementation discussions progressed, political attention in late 2025 moved beyond timing and towards the practical functioning of the Regulation. On 19 November 2025, the Council agreed its position to enter negotiations with the European Parliament on a targeted revision of the EUDR. These negotiations concluded swiftly, with the co-legislators reaching a provisional political agreement on 4 December 2025.
As part of this agreement, the co-legislators endorsed a further postponement of the application of the Regulation, coupled with targeted amendments aimed at facilitating implementation.
The revision seeks to simplify and clarify the application of the rules, reduce unnecessary administrative burden and improve legal certainty, while maintaining the Regulation’s core environmental objectives.
Under the revised timeline:
- The main due diligence obligations will apply from 30 December 2026 for large operators and traders;
- Micro and small operators will be subject to the rules from 30 June 2027;
- Micro and small operators already covered by the EU Timber Regulation will apply the EUDR from 30 December 2026.
These adjustments are intended to provide additional time for implementation, including further development and testing of the EU Information System.
What are the implications of the EU Deforestation-free Products Regulation for your business?
The Regulation introduces mandatory due diligence rules for businesses that place relevant commodities or derived products on the EU market, make them available on the market, or export them from the Union. The rules apply to commodities and products commonly associated with deforestation and forest degradation. Concretely, for businesses, the implications of the EUDR depend primarily on their position in the supply chain.
The Regulation distinguishes between two categories of economic actors:
- Operators, who placerelevant commodities or products on the European market for the first time or export them;
- Traders, who makerelevant commodities or products available on the European market after they have been placed by an operator
Obligations under the EU Deforestation-free Products Regulation
While there is a distinction in definitions between operators and traders, both actors have to follow the same due diligence obligations, which can be divided into three steps:
1. Collection of information
Documents and data showing that the product is deforestation-free and legal, such as geolocation coordinates, quantity, country of production, etc.
2. Risk Assessment
Assessment of whether there is a risk that the product does not comply with the rules laid down in the Regulation.
3. Risk mitigation
Adoption of risk mitigation procedures and measures if there is a significant risk that the product does not comply with the rules.
Under the targeted revision, the responsibility for submitting the due diligence statement via the EU Information System lies exclusively with the operator first placing the product on the EU market. Downstream operators and traders are required to retain and pass on the reference number of the initial due diligence statement, rather than submitting a new one.
All due diligence statements must be submitted electronically through the EU Information System to the competent national authorities.
The roll-out of the Information System remains aligned with the revised application timeline, with the system expected to be fully operational ahead of the main application date of 30 December 2026. The targeted revision further seeks to improve its usability and technical functionality in response to concerns raised by Member States and economic operators.
EUDR obligations for small and medium enterprises
A different scenario opens for those operators and traders who are small and medium enterprises (SMEs). In the case of SME operators or SME traders, both actors have fewer obligations and can rely on due diligence already carried out by traders or operators in their supply chain. However, SME operators still retain legal responsibility in the event of a breach of the EU Deforestation-free Products Regulation. SME operators and traders will also have more time to adapt, as their obligations will most likely apply from 30 June 2027 under the new delay.
Finally, operators sourcing commodities entirely from areas classified as low risk will be subject to simplified due diligence obligations, as they will only need to collect information and documents proving that the commodities are deforestation-free and legal.
Review clause, implementation challenges and business opportunities
Despite the postponement of the application of the EUDR to 30 December 2026, concerns around implementation, legal clarity and administrative burden remain central to the policy debate.
From an implementation perspective, many industries and EU Member States continue to raise questions about how the EU Deforestation-free Products Regulation will operate in practice. Although the European Commission has published several iterations of guidance, most recently in April 2025, both industry stakeholders and national authorities point to persistent ambiguities and express concerns about the additional administrative burden associated with compliance.
The postponement of the Regulation, together with the subsequent targeted revision, underlines the complexity of operationalising the due diligence framework and delivering a functioning EU Information System at scale. At the same time, the revised timeline provides businesses with additional time to prepare, test internal processes and adjust compliance systems ahead of full application.
The Regulation also includes a review clause requiring the European Commission to assess the impact and administrative burden of the EUDR, with a particular focus on micro and small operators. By 30 April 2026, the Commission must present a report identifying potential further simplification measures, including improvements to guidance and the EU Information System.
Beyond these challenges, the EU Deforestation-free Products Regulation also presents opportunities. Businesses that use the additional time to align early with the Regulation’s requirements can position themselves as credible and resilient actors within deforestation free supply chains. In doing so, they may strengthen their sustainability credentials, reduce future compliance risks and enhance their competitive position within their sector.
What are the next steps for the EU Deforestation-free Products Regulation?
For businesses within scope of the EUDR, the focus now shifts from headline deadlines to how the revised rules will be applied in practice. This means closely following the formal adoption and national implementation of the targeted revision, as well as forthcoming Commission guidance clarifying operational aspects of the Regulation. While the core due diligence framework remains unchanged, the agreed adjustments are likely to influence compliance strategies, internal reporting processes and interactions with competent authorities.
In parallel, attention will turn to the simplification review mandated by the co-legislators. By 30 April 2026, the European Commission is required to assess the EUDR’s impact and administrative burden, with a particular focus on smaller operators. The review may lead to further clarifications or adjustments, including improvements to guidance and the EU Information System, which could shape how the Regulation functions in practice over time.
Against this evolving backdrop, businesses benefit from a structured approach that combines regulatory monitoring with practical implementation planning. Understanding how EU-level decisions translate into national enforcement, and how upcoming reviews may affect compliance expectations, will be key to managing risk and avoiding last-minute adjustments.
We at Publyon support organisations in navigating this evolving policy landscape by translating regulatory developments into concrete operational and strategic implications. Through targeted impact assessments and public affairs support, we help organisations anticipate change, engage with decision-makers and position themselves effectively as EU sustainability rules continue to take shape.
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