The European Commission has proposed pushing back the EUDR enforcement date, but that doesn’t mean the regulation is any less urgent. The core obligations remain the same, and companies importing or trading covered commodities will still need to demonstrate full traceability and compliance.

Several major industry players, including Ferrero and Mars, represented through their trade associations, have already criticised the idea of a delay. In a statement cited by Cocoaradar.com, they warned that postponing the EUDR “puts the world’s forests at risk and weakens confidence in Europe’s environmental commitments.”

Rather than a pause, this proposed delay should be seen as a brief window to get smarter about EUDR preparation in 2025. It's a chance to test due diligence processes, strengthen supplier data, and avoid the pitfalls of last-minute compliance. 

This article outlines five practical actions compliance teams can take now to stay ahead, focus resources effectively, and be ready when enforcement begins.

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If the deadline shifts, does EUDR prep still matter?

Yes. A later enforcement date changes the timeline, but it doesn’t change the regulation itself. The core requirements: full traceability, deforestation-free sourcing, and due diligence statements, remain in place. Whether compliance begins in 2025 or later, companies will eventually be held to the same standard.

The risk lies in waiting. Early movers already engaging suppliers, collecting geolocation data, and testing compliance systems will be better positioned to adapt to updates in the regulation. They’ll also minimize the chance of bottlenecks when enforcement begins, avoiding last-minute scrambles, audit failures, and potential disruptions to trade.

Think of the delay as extra time to refine, not as an excuse to pause. Companies that keep momentum now will not only hit compliance faster but also gain operational resilience and smoother supplier relationships.

Should we pause preparation or keep going?

A delay doesn’t mean exemption. The EUDR will still come into force and waiting only makes compliance harder.

Companies that pause now risk facing:

• Supplier bottlenecks when everyone starts requesting data at the same time.
• Rushed due diligence statements that increase the chance of errors.
• Incomplete data that won’t stand up to audit scrutiny.
  

Continuing preparation, even under a postponed deadline, gives you optionality. You can build leverage with suppliers, identify blind spots early, and decide how to pace your investment. Those who use this time proactively will have a smoother, lower-cost path to compliance than those scrambling later.

What compliance tasks should we prioritize now?

Not every task needs to be completed immediately, but some take longer to establish and are critical for avoiding roadblocks later. Companies should focus first on the areas with the longest lead times and the highest impact:

Supplier engagement and geolocation collection

Getting accurate plot-level data from suppliers takes persistence. Early outreach helps avoid delays and builds the relationships needed for smooth data exchange.

Legal documentation, risk assessments, and mitigation

Collect land-use permits, labour rights documentation, and other legal records now. These can be time-consuming to source, especially across multiple jurisdictions. 

At the same time, begin mapping risks and defining mitigation steps for higher-risk suppliers or regions. This groundwork will make your due diligence process more defensible later.

Internal mapping of roles

Clarify whether your company is acting as an operator, a trader, or both. This affects your reporting obligations and ensures responsibilities are clearly assigned.

Initial DDS formatting and dry runs

Test your due diligence statements before they’re required. Running mock submissions highlights gaps in data and prepares teams for real enforcement.

Focusing on these “long runway” tasks now reduces the risk of scrambling later and creates a foundation you can build on once timelines are confirmed.

How can we use the delay to refine supplier data and risk logs?

A postponed deadline gives you some valuable time to improve the quality and reliability of your supplier data - work that can’t be rushed once enforcement begins. Instead of ticking boxes, use this period to standardize, verify, and version your data so it can stand up to scrutiny later.

1. Verify and standardize plot-level data

Review all supplier coordinates to ensure they’re accurate, complete, and formatted consistently. Discrepancies are one of the most common causes of delays in due diligence submissions. Our EUDR country benchmarking guide can help you identify higher-risk sourcing regions and prioritize verification accordingly.

2. Assess supplier maturity

Run short supplier maturity assessments to gauge how well your partners understand and meet EUDR requirements. This helps flag suppliers needing extra support, reducing surprises when compliance becomes mandatory.

3. Keep risk logs versioned and traceable

Update your risk scores regularly and maintain clear version control. Every document upload or adjustment should leave a visible record. That audit trail will be invaluable later when preparing your EUDR due diligence statement for TRACES submission.

For official guidance and background, see the European Commission’s Deforestation Regulation portal.

How can we avoid wasting resources during uncertainty?

A shifting timeline doesn’t mean progress should stop. It just calls for smarter prioritization. The best approach is to split your EUDR preparation into “no-regret” actions and timeline-sensitive tasks.

1. Focus on no-regret actions

Some steps pay off no matter when enforcement begins. Supplier data collection, internal training, and risk mapping all strengthen your compliance position. See our EUDR compliance guide for key actions to take now.

2. Use modular preparation

Run due diligence on your supplier and origin data at the source level, rather than the order level. This approach makes the data reusable across future transactions and helps you build a consistent, scalable foundation. It’s also a valuable way to assess supplier performance and identify where additional support or verification may be needed.

3. Prioritize reusable documentation

Skip static PDFs that quickly go out of date. Keep versioned, reusable records with clear change histories. They’ll serve both EUDR and broader ESG reporting needs.

Follow the European Commission’s deforestation-free products page for ongoing implementation updates.

What does “stress-testing compliance” look like in practice?

A proposed delay is the perfect time to test how your due diligence system performs under real conditions. Running controlled “stress tests” exposes data gaps, process weaknesses, and supplier issues before enforcement begins.

1. Simulate a real DDS submission

Run test submissions using actual supplier data to see how your system performs under real conditions. You can simulate DDS submissions using the test version of TRACES available through the European Commission’s acceptance environment. This helps confirm whether your due diligence statements are formatted correctly and align with TRACES requirements.

To make it practical, take a few random orders and walk through the full process:

• Do you have complete supplier information and maturity data?
• Can you trace the order back to its origin?
• Is the required documentation for legality and deforestation-free sourcing in place?
• Does the risk assessment meet the EUDR standard?
• If risks are flagged, do you have defined mitigation steps?

2. Conduct mock audits or peer reviews

Invite colleagues or external partners to review your process as if they were auditors. Focus on common weak spots like missing coordinates, unclear supplier relationships, or role misclassification between operators and traders.

3. Test for system readiness

Ensure your compliance platform mirrors real-world enforcement. Tools like Coolset’s EUDR solution can flag issues such as data gaps or nonstandard formats before submission. For best practices, see our EUDR risk assessment guide.

FAQs

Let’s take a look at some common questions around how to act given the proposed new timeline.

Should we pause EUDR preparation if the deadline is delayed?

No. A delay changes timing, not requirements. The core obligations: traceability, deforestation-free sourcing, and due diligence statements remain the same. Continuing preparation now helps prevent supplier bottlenecks, rushed submissions, and compliance gaps later.

What are the highest-priority tasks under a postponed timeline?

Focus on long-lead actions like supplier engagement, geolocation data collection, legal documentation, and risk assessments. These take the most time and are foundational to compliance. Early progress here gives you flexibility once the new enforcement date is confirmed.

How can we make supplier data more audit-ready?

Standardize and verify all plot-level coordinates, update risk logs with clear version histories, and maintain traceable documentation for each supplier. Tools like maturity assessments or risk scoring frameworks make it easier to identify weak spots before audits.

What does “modular compliance” actually mean?

It’s a flexible approach that separates immediate, low-risk actions from those that depend on final guidance. For example, you can collect and structure supplier data now but wait to upload it into your compliance software until TRACES formats are confirmed. Modular prep prevents rework while keeping progress on track.

How can I simulate TRACES-ready due diligence?

Run mock due diligence statement submissions using real supplier data. You can use the TRACES test environment to simulate DDS submissions and verify your data readiness. Check for incomplete coordinates, role misclassifications, and missing documents. 

Platforms like Coolset’s EUDR solution can also help mirror TRACES requirements and flag formatting issues before enforcement begins.