If EUDR is delayed, does EUTR still apply?

The EU Timber Regulation (EUTR) entered into application on the 3rd of March 2013, and was put in place to prohibit the placement of illegally harvested timber on the EU market. It’s set to be replaced by its more comprehensive counterpart, the EU Deforestation Regulation (EUDR), when it enters into application on 30 December 2025. However, with the recent whisperings of a delayed EUDR due to a letter sent from the European Commission, uncertainty has arisen. Does the EUTR still apply if the EUDR is delayed? 

Short answer: Yes - the EUTR continues to apply in full until the EUDR is officially implemented and replaces it. Good to keep in mind - currently, despite rumours, no formal delay has been adopted so the implementation date of the EUDR (and thus the repeal date of the EUTR) remains to be 30th December 2025 for medium and large businesses, and 30 June 2026 for small and micro. We recommend keeping up to date with regulatory changes in the EU.

{{custom-cta}}

The legal baseline - EUTR remains in force

The legal baseline is straightforward: EUTR will remain in force until the moment EUDR is implemented and the EUTR is formally repealed by it. In EU law, the EUDR includes a clause to repeal the EU Timber Regulation (995/2010), but only once the new rules officially kick in. This means all provisions of EUTR continue to operate during any postponement of EUDR’s start date. 

Practical example: In late 2024, EU legislators approved a 12-month extension of EUDR’s phase-in timeline, shifting its applicability to December 30, 2025 for large/medium companies and June 30, 2026 for small and micro enterprises. As a result, EUTR’s life was effectively prolonged by one year as well. 

Recently, a letter sent by Jesskia Roswall, the EU Environment Commissioner, to the European Parliament and Council set in motion the potential process for another one year delay. While the current deadlines remain in place until the European Commission formally proposes a change, and both Parliament and Council approve it, there is uncertainty in the air about current EUDR and EUTR obligations. 

Even with the EUDR delay, the EUTR rules still apply. The European Commission has confirmed that any timber placed on the market before the EUDR takes effect remains covered by the EUTR, in some cases right through to 2027 or 2028.

So in practice, a delay doesn’t mean a break in enforcement. Companies importing or trading timber still need to follow all the EUTR due-diligence, documentation, and legality checks. National authorities will keep enforcing these rules as usual, there’s no leniency just because EUDR is on hold.

That means illegally harvested timber is still banned, and operators must keep doing risk assessments and record-keeping as required under the EUTR. Only once the EUDR officially starts will the EUTR stop applying and even then, just for timber harvested after the new regulation’s start date. In short: until EUDR fully replaces it, EUTR stays in force, and ignoring it would still count as breaking EU law.

In short, a postponed EUDR = an extended EUTR. Compliance teams should act accordingly by continuing to meet EUTR requirements for as long as it remains active. Next, we’ll look at how EUTR and EUDR differ, and why EUTR still matters so much during this transition period.

What if my timber products were produced before the entry of EUDR?

As mentioned above, the EUDR entered into force on 29 June 2023. This differs from its entry into application, which is set to happen on the 30 December 2025. Therefore, for products produced before the entry into force of the EUDR (29 June 2023), the EUTR will continue applying until 31 December 2027. For example, timber harvested in January 2023 must continue to be covered by EUTR requirements until December 2027. 

EUTR vs EUDR - similarities and differences

Even though EUTR and EUDR share the overarching goal of curbing deforestation and illegal logging, they differ significantly in scope and stringency. 

Commodities covered

• EUTR: Timber and timber products only (focused on wood).
• EUDR: Broader scope: covers timber plus cattle (beef, leather), soy, palm oil, coffee, cocoa, and natural rubber.

Main requirements

• EUTR: Legality of timber: must ensure timber was legally harvested under origin-country laws. No explicit deforestation criteria.
• EUDR: “Deforestation-free” and legal: must prove products were not produced on land deforested after Dec 31, 2020 and comply with local laws. Stricter criteria include forest degradation (for wood) and legality.

Geographic scope

• EUTR: Applied to timber imported into the EU (first placement on EU market). EU-produced timber wasn’t explicitly covered by EUTR’s due diligence (though Member States had to ensure legality domestically).
• EUDR: Applies to all relevant commodities placed on or exported from the EU market, regardless of origin. This means EU producers of these commodities also have to meet EUDR standards, eliminating distinction between imports and domestic supply.

Due diligence process

• EUTR: Require a Due Diligence System (DDS) for timber: collect info (species, origin country, supplier), assess risk of illegality, mitigate risk, keep records. No mandatory pre-reporting to authorities; enforcement via inspections.
• EUDR: More extensive DDS: must collect detailed data (e.g. geolocation coordinates of farm/plot, production date), assess risk of both illegality and deforestation, mitigate, and submit a due diligence statement (DDS) to a central system (e.g. TRACES) for each shipment. Due diligence obligations are uniform across all commodities (with potential simplifications for low-risk countries).

Risk assessment:

• EUTR: No formal country risk tiers in regulation (aside from FLEGT-licensed timber, which was automatically considered legal). Risk determination left to operators’ judgment and available info.
• EUDR: Risk-based enforcement: introduces country benchmarks (low, standard, high risk) to adjust scrutiny levels. Initially, low-risk origins would allow simpler due diligence and fewer inspections. (However, the first proposed risk list was rejected, so companies should be ready to perform full due diligence for all sources until a new system is in place.)

Penalties

• EUTR: Set by each Member State - typically fines (ranging from hundreds to millions of Euros depending on the country) and even criminal penalties. For example, violations can incur unlimited fines or up to 2 years imprisonment in the UK, and up to 10 years imprisonment in Greece. 
• EUDR: Harmonized baseline penalties: EUDR mandates minimum penalties (e.g. fines at least 4% of a company’s EU turnover for non-compliance), aiming for more uniform and dissuasive consequences. Member States may still add further penalties (including criminal ones) but EUDR raises the bar on enforcement consistency and severity.

EUTR and EUDR share DNA (both aim to keep unsustainable timber/forest-risk products out of the EU), but EUDR is broader and stricter. However, until EUDR is active, EUTR is the law and its more limited scope is still fully enforceable. 

Companies must continue following EUTR (ensuring timber legality through due diligence) even as they gear up to meet the coming EUDR obligations (deforestation-free supply chains for multiple commodities). 

The next sections outline what businesses should be doing during this limbo period.

What should companies do now?

If you’re a company affected by both of these regulations, you have a dual task: stay compliant with EUTR today, while preparing for EUDR tomorrow. Here’s what to focus on in practical terms.

Stay compliant with EUTR obligations

Do not take the foot off the pedal on EUTR due diligence. Competent authorities in EU countries are still actively checking companies for EUTR compliance. Ensure your due diligence system for timber is up-to-date – this means gathering all required documents (e.g. supplier declarations, harvesting permits, FLEGT licenses if applicable), assessing risk of illegality for each timber shipment, and mitigating any identified risks. Continue to keep records of suppliers and buyers as required. In short, keep acting in accordance with EUTR – it remains fully in force, until EUDR comes into application. Any illegal timber slipping through now can lead to penalties just as it would have before. 

Build on EUTR foundations to prepare for EUDR

While there is uncertainty on the implementation date of EUDR, what remains certain is the complexity of the new regulation. Use this time, delay or no delay, to get prepared. 

In fact, in a recent poll, Coolset found that 91% of companies said they are continuing their EUDR preparation despite the proposed delay. The consensus is that a delay is a chance to prepare better, not a reason to stop. Even if the deadline is extended, any extra time should be seen as bonus time to test and refine your compliance processes. 

Start piloting EUDR-specific tasks

The EUDR is a more complex version of the EUTR, with a broader scope, stricter due diligence requirements and comprehensive geolocation requirements. Therefore, the potential delay offers the chance to get clear on exactly what the EUDR requirements are, and how you can implement these requirements into your organisation. 

Begin by mapping all in-scope products and suppliers as the EUDR extends beyond timber, to include commodities like paper/packaging (wood), beef and leather (cattle), soy ingredients, palm oil in products, cocoa/chocolate, coffee, and rubber. Catalog all products you import or trade that contain these materials, then list all the suppliers and sources for those products. This exercise will tell you the breadth of what EUDR due diligence you’ll need to perform. 

One of the hardest new tasks under EUDR is obtaining the geographic coordinates of where commodities were produced (e.g. the exact farm or plantation). Beginning to engage suppliers now will help you later on, as it is likely to take time to achieve full traceability of your supply chain. 

The EUDR’s risk assessment requirement also requires engagement from suppliers, who should support by providing documents such as legal harvesting permits and evidence of legal employment on their plots. If you have many suppliers, consider segmenting them by risk, and beginning with those from the highest risk countries. The EUDR is set to affect whole supply chains, so it is important to engage both internal and external stakeholders. Training staff, hosting workshops, designating responsibilities and confirming budgets is a great place to start.

In short, an EUDR delay isn’t a free pass, it’s a wake-up call. The EUTR still stands, and the smartest companies are using this extra time to tighten their due diligence and get ahead of the curve. The mission hasn’t changed: Europe still expects deforestation-free, legal supply chains.

Those who stay proactive now won’t just stay compliant, they’ll be better positioned to lead when the EUDR finally kicks in. Treat this pause not as a break, but as a strategic window to turn sustainability compliance into a real competitive edge.

How does software help bridge EUTR and EUDR?

Managing the parallel demands of EUTR and impending EUDR can be challenging, especially for companies with limited compliance resources. This is where compliance software can step in, bridging the two frameworks and reducing the load on teams. A good system will help you handle current EUTR tasks while seamlessly scaling up to EUDR requirements when the time comes.

For example, Coolset’s sustainability platform covers both EUTR and EUDR requirements by design. You can use one centralized system to collect supplier information, document due diligence steps, and store all evidence - satisfying EUTR’s record-keeping needs today - and that same system is already equipped to accommodate EUDR’s stricter workflows (like mapping geolocations and preparing the official EUDR Due Diligence Statements). 

Centralized supplier data and document management: Instead of juggling spreadsheets and emails, a platform allows you to request and store all supplier documents in one place. For EUTR, this means you can compile legality documents (e.g. logging permits, certificates) per supplier and shipment. For EUDR, you will be able to add on documents like satellite proof of deforestation-free status or farm GPS coordinates.

Integrated risk assessment and audit trail: Software can guide you through the due diligence process step by step. Moving from EUTR to EUDR requires extended risk assessments, such as checking for deforestation on a given co-ordinate. Coolset’s platform automatically highlights shipments from high-risk areas and missing data, prompting your team to act. The result is a complete audit trail of how you’ve handled due diligence for each batch - something both EUTR inspectors and EUDR auditors will appreciate.

Automated compliance checks and DDS generation: One of the headaches companies anticipate with EUDR is generating and submitting the official Due Diligence Statement for every shipment. Compliance software can automate much of this. By storing all necessary info (product CN codes, country of origin, geolocation, risk rating, etc.), the system can compile the DDS file in the required format at the click of a button. Coolset’s EUDR module, for example, automatically uploads audit-ready DDS files to EU TRACES, meaning you never have to leave the Coolset platform. 

Using a purpose-built platform ensures that there is no disconnect between EUTR compliance and EUDR readiness - it’s one continuous process. In fact, many companies are adopting software now precisely to avoid having to “re-invent the wheel” for EUDR. The Coolset system already covers geolocation and TRACES submission features alongside traditional EUTR due diligence, so businesses won’t need to overhaul their process when the new law kicks in. 

FAQs

Does EUTR still apply if EUDR is delayed?

Yes. EUTR remains enforceable until EUDR officially replaces it. The delay simply extends EUTR’s lifetime, meaning timber due diligence and legality checks remain mandatory until at least December 30, 2025, and longer if the proposed delay is adopted.

What are the penalties for non-compliance under EUTR?

Penalties vary by country but can include fines of up to millions of euros, product seizures, and even prison sentences. Enforcement remains active, so non-compliance during the delay carries real legal and financial risks.

Which EU practices help prepare for EUDR?

Keep strong supplier traceability, legality documentation, and risk assessment systems. These form the foundation for EUDR’s added requirements on deforestation-free sourcing and geolocation data.

Should companies pause EUDR preparation? 

No. A delay changes the timeline, not the rules. Continue preparing by improving traceability, training suppliers, and testing systems. Any groundwork done now will remain fully relevant when EUDR takes effect.

Will EUTR enforcement continue during delays of EUDR?

Yes. National authorities are expected to keep enforcing EUTR rigorously until its repeal. Companies should assume full compliance checks will continue throughout the transition period.