Introduction to EUDR compliance timelines - what to do and when

The EU Deforestation Regulation (EUDR) is on a fixed timeline – and failing to prepare in time can mean costly disruptions. Large and medium companies face a 30 December 2025 compliance deadline, while small and micro enterprises have more time, until 30 December 2026 according to the latest EU proposal. These staggered dates give companies a transition period, but that time can slip away quickly.

Preparing in well-defined phases helps ensure nothing is left to the last minute. EUDR compliance cannot be completed in a single action; it requires integrating new workflows into your operations, contacting suppliers and collecting information. Failing to comply by the deadlines increases the risk of shipment blocks, fines, or scrambling to meet requirements under pressure.

The EU has already granted an extra 12-month phase-in as many firms weren’t ready by 2024, with the European Commission noting this extra time is a ‘valuable window’ to strengthen readiness. Additionally, on 21 October 2025, the European Commission proposed a phased enforcement plan that maintains the 30 December 2025 deadline for large and medium operators but extends compliance for small and micro operators to 30 December 2026. This proposal is currently under review and not yet legally adopted.

What are the EUDR deadlines?

The key EUDR enforcement dates are as follows:

What is the grace period introduced in the latest EUDR proposal?

In its October 2025 proposal, the European Commission introduced a six‑month grace period for large and medium operators from January to June 2026.

During this phase, regulators are expected to prioritise guidance over penalties, giving companies time to adjust systems and fix gaps.

However, this is not a delay - all due‑diligence, traceability and reporting obligations still apply from 30 December 2025 for large and medium operators. The grace period softens early enforcement while full compliance remains mandatory.

What should companies do in Q3-4 2025, for EUDR?

For large and medium-sized enterprises (those with a December 2025deadline), the second half of 2025 is the make-or-break period to get EUDR compliance over the finish line. By Q3 2025, you should be deep into implementation. By Q4 2025, everything should be in place so you can “go live” by the December deadline. Here is an action plan for what do to in H2 2025:

Engage and onboard suppliers (August - September 2025)

If any supplier data is still missing, now is the time to fill the gaps. Reach out upstream - farmers, producers, traders - and clearly explain the data you need, such as GPS coordinates of farms, proof of land legality, and other origin information. The information you require will vary between suppliers, based upon their position in the supply chain and the country in which they operate in.

Many suppliers, especially in origin countries, might be unfamiliar with these requirements. Use this period to identify any unprepared suppliers and assist them (with templates, training, etc.). Early engagement is critical because suppliers vary in readiness; the sooner you spot issues, the more time you have to resolve them. For example, a coffee importer working with hundreds of smallholder farmers should start collecting farm GPS points and forest-cover evidence by Q3 2025 – this can easily take months of coordination in remote regions.

Inventory products and map HS codes

Make an exhaustive list of all commodities and products your company deals in, and check them against EUDR’s scope. The regulation covers not just raw materials but also many derived products (e.g. chocolate, leather goods, paper). For each in-scope item, determine its CN/HS code and verify it’s listed in EUDR’s Annex I. This exercise ensures no product line is overlooked.

If you haven’t done this by mid-2025, do it now – mapping your entire product catalog to the regulated list will clarify which supply chains need due diligence. (As a sector example, a leather goods manufacturer should confirm whether all types of leather and hides they use are listed under the cattle-derived products in Annex I. This influences which suppliers – e.g. tanneries or slaughterhouses – they must gather data from.)

Select your due diligence tools and systems

By Q3 it is important to know how you will manage the data and workflow for EUDR compliance. Some companies build internal systems; others adopt third-party software. The key is to have a central repository for all required information (geolocation coordinates, supply chain documents, risk assessments) and a mechanism to generate the due diligence statements (DDS) for each shipment.

Ensure your solution can handle shipment-level data and keep an audit trail. If you’re still using spreadsheets at this stage, consider migrating to a more robust tool that supports EUDR’s detailed record-keeping and risk analysis needs. Remember, every batch will need a DDS, so your system should make it as streamlined as possible.

DDS preparation

As of October 2025, all countries remain classified as standard risk under the EUDR. The European Parliament rejected the Commission’s proposed country benchmarking system in July 2025, meaning no country currently benefits from a “low‑risk” designation. All imports therefore require full due diligence - including geolocation, legality documentation, and risk assessments - regardless of the country of origin.

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Train your team and simulate the process

Q4 2025 is time to make sure all relevant staff know their roles in EUDR compliance. Procurement, sustainability, and logistics teams should understand how to collect data and when to trigger a DDS submission. It’s wise to practice creating and submitting a DDS ahead of the deadline. The European Commission’s EUDR online portal (built on the TRACES platform) offers a training environment where companies can register and simulate filing a due diligence statement. By practicing in the TRACES test system, your team can get comfortable with the interface and ensure you know what information is required for each submission.

Run an internal dry-run drill: for instance, take one high-risk supply chain and go through all steps – collect its data, perform a risk assessment, and generate a dummy DDS – as if you were shipping under EUDR already. This “pilot” will quickly highlight any bottlenecks or missing information while you still have a few months to fix them. It’s much better to discover in October 2025 that, say, your palm oil supplier can’t provide precise plot maps, than to discover it in January 2026 when your shipment is stuck at customs.

Solidify risk assessment and mitigation plans

By late 2025, large/medium companies should have a clear process for evaluating deforestation risk in each supply chain. If any sourcing regions are identified as higher risk (e.g. commodities from areas with known forest clearance), have mitigation measures ready. This could include obtaining additional evidence from suppliers, conducting third-party audits, or even adjusting your sourcing if necessary.

The goal by Q4 is that for every in-scope product you will place on the market after Dec 30, 2025, you have documented proof it’s “negligible risk” (no recent deforestation or illegality) and can show how you reached that conclusion. Use the remaining time to close any gaps in evidence. For example, if a plantation’s satellite imagery is unclear, get updated imagery or on-the-ground verification now. By the deadline, you want zero guesswork about compliance for each product.

By following this Q3–Q4 2025 plan, large and medium enterprises can enter the enforcement date with confidence. In summary, don’t leave onboarding, system setup, or trial runs until the last minute. As one expert guide put it, waiting until just a few months before the deadline is too late - companies should use the transition period to “start mapping their supply network, collecting documents, and even run a dummy due diligence workflow” so that there’s no last-minute scramble.

What should be ready for December 2025 to comply with EUDR?

As 30 December 2025 looms, large and medium companies need to wrap up any loose ends and ensure they are truly audit-ready. Consider the weeks leading up to the deadline as a “freeze” period for your compliance project – everything should be tested and in place by then. Key tasks to complete before the EUDR goes live include:

Finalize and submit initial DDS (if applicable):

The DDS is an official declaration confirming that due diligence has been carried out and that the product meets EUDR requirements. You won’t submit DDSs before the law takes effect, but from 30 December 2025 onward, every in-scope shipment placed on or exported from the EU market must be covered by one.

Some companies plan to avoid imports in the final days of 2025 to prevent transitional issues, while others may test the TRACES system if voluntary submissions are possible. At minimum, prepare a complete DDS example for a representative shipment to ensure you can generate and submit them consistently and accurately once enforcement begins.

Ensure internal process and team readiness

By early December 2025, your EUDR compliance process should be fully integrated into internal workflows. This means roles and responsibilities are assigned and documented; and everyone is trained on the process or software you are using to manage EUDR compliance.

The end of 2025 is also a good time to update any internal SOPs or checklists to align with EUDR. For example, your import department’s standard operating procedure should now include “Verify DDS reference is obtained before shipment release” as a mandatory step.

Audit readiness check

Treat the pre-deadline phase as a final internal audit of your due diligence system. Verify that all required Article 9 information (geolocation, legal documents, etc.) is collected for each relevant supplier, and the evidence is correct, accurate and easily accessible.

Simulate an authority audit by ensuring you can pull up any required record within a few hours if asked. A defensible compliance system depends not just on doing the work, but on organizing evidence so it can be presented clearly.

Finalise risk mitigations

Going into 2026, there should be no pending questions about the compliance of products you will place on the market. If something cannot be fully resolved (say a supplier still hasn’t provided a needed document), make a business decision: either delay importing that product or source it elsewhere until you have certainty. It’s better to pause a shipment than to risk a violation.

Communicate with partners

Finally, loop in your downstream and upstream partners about the switch-on of EUDR. Inform your customs brokers or freight forwarders that, as of the end of 2025, every shipment will need a DDS reference number – they should be ready to include that in customs declarations.

Likewise, inform customers (especially if you are a B2B supplier) that you are EUDR compliant and what new documentation they might see. Clear communication ensures no surprises in the supply chain when the regulation takes effect.

Under the October 21 proposal, competent authorities would apply a six-month grace period from January to June 2026 for large and medium operators. During this time, enforcement would focus on education and support rather than penalties. However, legal obligations still apply - operators are expected to comply from day one.

How you should plan as an SME for EUDR in 2026

Small and micro enterprises may gain until 30 December 2026 to comply with the EU Deforestation Regulation (EUDR) - if the European Commission’s October 2025 proposal is adopted. This proposal is still under review by the European Parliament and Council, so the timeline is not yet legally binding. Until formal approval, the only binding enforcement date for SMEs remains 30 June 2025.

If you’re a small operator, treat 2026 as your ramp-up year - not a pause.

• Confirm your company size. Check if you qualify for SME or micro enterprise:
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  • Small: <50 employees or ≤€10M turnover
  • Micro: <10 employees or ≤€2M turnover

If you exceed either threshold, the 2025 deadline applies.

• Kick off compliance early: if you didn’t start in 2025, begin in January 2026 at the latest. Start by educating yourself on the basics, then perform the same fundamentals as larger firms.

• Take advantage of simplified procedures: The regulation builds in certain simplifications for SMEs to ease their burden. Notably, if you are a downstream SME operator (i.e. you source a product that already came with a DDS from an upstream operator), you don’t have to redo the entire due diligence. You can simply collect and record the reference number of the existing DDS. Become familiar with these simplifications – they can save you effort.

• Focus on risk screening and priority areas: With limited staff, SMEs should prioritise high-risk supply chains first. Look at your commodities and countries of origin. If you’re sourcing cocoa from a region with active deforestation, or rubber from a country likely to be classified as high-risk, focus your due diligence efforts there first.

• Leverage external resources: Small businesses shouldn’t go it alone. Use the first half of 2026 to leverage industry associations, EU guidance, and available tools. The European Commission has published guidance documents and an FAQ tailored for understanding EUDR. Industry groups for coffee, cocoa, timber, etc., often provide templates or collective solutions for members.

• Finalize SME compliance: Use the second half of 2026 to tie everything together. Much like larger companies did earlier, test out preparing a DDS (if you’re an operator). Even SMEs will use the same EUDR Information System to submit statements for any imports/placements. So try registering in the system as soon as possible, and submit a dummy statement if possible in the training environment.

Ongoing EUDR tasks once compliance begins

Reaching the enforcement date is not the end of the journey – it’s the start of continuous compliance. After EUDR requirements kick in (Dec 2025 or Dec 2026, depending on company size), businesses need to incorporate due diligence into regular operations and keep it up-to-date. Here are the ongoing tasks and best practices after the law is in effect:

• Embed due diligence in routine workflows
• Maintain supplier monitoring and engagement
• Regularly update due diligence data
• Document and record-keep meticulously
• Prepare for audits and reporting
• Keep informed about regulatory changes

In essence, after the enforcement deadlines, companies enter a phase of continuous improvement and vigilance. Regular due diligence updates, periodic internal audits, and responsiveness to new risks or rules will characterize the compliance landscape. By doing so, you’ll not only meet your legal obligations but also build trust with customers and regulators that your supply chain remains clean over time.

FAQs - EUDR task timing and coordination

1. When should we start preparing for EUDR compliance?

Start preparing for EUDR immediately – the earlier, the better. Large and medium companies ideally should have begun in 2024 or early 2025 to meet the Dec 2025 deadline. If you haven’t, start now; don’t wait until a few months before the law applies. Small and micro companies with the proposed December 2026 deadline should use the extra time but still aim to have their systems in place well before that date. In short, give yourself at least 6–12 months of lead time for all the data gathering and process setup.

2. What if the data we need for EUDR compliance (e.g., satellite images or documents) aren’t readily available?

If you encounter a data gap (for instance, a supplier can’t provide a precise plot map) in your EUDR preparations, consider sending an independent verifier or using a service that can generate that data. EUDR products are built to support you meeting your data requirements.

In worst-case scenarios, if you truly cannot get sufficient data to assess a supply chain, you may need to halt sourcing from it until compliance can be confirmed. It’s better to have a temporary pause than to risk non-compliance due to missing information.

3. How do we deal with suppliers who are slow or unresponsive in supplying EUDR information?

Supplier responsiveness in the EUDR compliance process is a real challenge – which is why engaging them early is so important. If a supplier is slow to respond, try breaking down requests into simpler tasks, or offer help. For example, if a farmer cooperative isn’t providing GPS coordinates, you might use an approximate location they gave and find the coordinates yourself, then ask them to confirm. Sometimes language or technology barriers are the issue – provide translated instructions if needed, or have a local agent assist.

In the extended run-up to the deadlines, some companies have even dropped high-risk, non-cooperative suppliers and onboarded new ones who can demonstrate traceability. Use carrots and sticks: let suppliers know compliance is a condition for doing business going forward (and after 2025/2026 it’s legally non-negotiable).

4. Can we practice submitting a Due Diligence Statement before we actually have to do it?

Yes. The European Commission has provided a training environment on the EUDR Information System (TRACES) where companies can log in and simulate the DDS submission process. It’s highly recommended to use this sandbox. You’ll learn what fields are required, how to attach supporting documents, and how to retrieve the DDS reference number.

5. After we comply by the deadline, is there anything else to do?

EUDR compliance is ongoing and iterative, not a one-off task. After the deadline, you need to continuously ensure each new product or shipment is compliant – deforestation-free, legal, and backed by due diligence. Supply chains are dynamic, so you must monitor for changes (new sourcing areas, expansions into forest frontiers, etc.). At minimum, conduct a full review of your due diligence system annually as required by the regulation. In practice, many companies will do more frequent spot-checks – for example, a monthly review of a sample of DDS submissions for accuracy.