EUDR compliance timeline: What to do and when (Updated June 2026)

October 23, 2025
8
min read
EUDR compliance timeline: What to do and when before the 2025 and 2026 deadlines (Updated Oct 2025) - Coolset
Table of contents

Disclaimer: New EUDR developments - December 2025

In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.

Key changes proposed:

  • New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
  • Simplified DDS: One-time declarations for small and micro primary producers
  • Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
  • New DDS requirement: Estimated annual quantity of regulated products must be included

These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.

We continue to monitor developments and will update all guidance as the final law is adopted.

Key takeaways:
  • Large and medium companies must be fully EUDR-compliant by December 30, 2025, with inspections starting mid-2026. Small and micro enterprises may get until December 2026, as per the October 21 EUDR proposal. This is pending EU approval.
  • Compliance requires early supplier onboarding, GPS data collection, DDS preparation, and risk assessments - delays risk shipment blocks or fines.
  • Coolset simplifies EUDR timelines with supplier engagement tools, DDS automation, and audit-ready documentation workflows.

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 2026 compliance deadline, while small and micro enterprises have more time, until 30 June 2027 for non-timber products. These staggered deadlines give companies different windows to prepare, but the work needed is substantial in either case.

This timeline guide gives you a clear view of what to do and when, whether you’re just getting started, mid-preparation, or refining an existing compliance program. It covers both strategic milestones and operational tasks so you can map out your own EUDR readiness plan.

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Key EUDR deadlines at a glance

Before diving into the timeline, here’s a quick overview of the key dates:

Image: EUDR compliance timeline 2026/2027. Source: Coolset.

Phase 1: Readiness and scoping (Now – Q2 2026)

Most companies should be deep in this phase now or moving to the next one.

Confirm your scope

Identify which products, commodities, and supply chains fall under the regulation. Check every product against Annex I to confirm whether you're in scope. This includes identifying your role – operator, downstream operator, or trader – for each product line you handle.

Map your supply chain

Trace your supply chains from finished product back to the plot of land where each commodity was produced. For each commodity, identify your suppliers and, where possible, the plots of origin. This is the foundation for your due diligence system.

Assess country risk

Once you know your supply chain origins, check each country against the EUDR country risk classification (adopted May 2025). Low-risk countries trigger simplified due diligence. Standard- and high-risk countries require full due diligence including risk assessment and mitigation.

Engage key suppliers

Reach out to your direct suppliers to explain what data you will need from them: geolocation coordinates, production dates, legality evidence, and deforestation-free documentation. Supplier engagement is typically the longest lead-time item in any EUDR compliance program. Start early.

Phase 2: Data collection and system building (Q2–Q3 2026)

This is where compliance programs become operational.

Collect geolocation and legality data

Gather GPS coordinates (GeoJSON format) for all plots of land where your commodities were produced. For cattle, this means all establishments involved in raising the animals. Alongside geolocation, collect the legality documentation required under Article 9 of the EUDR: permits, land titles, certifications, and any other evidence showing the product was legally produced in the country of origin.

Build or configure your due diligence system

The EUDR requires a formal due diligence system under Article 12. This is the documented set of procedures and processes your company uses to collect information, assess risk, and implement mitigation measures. It must be reviewed at least annually. Many companies use specialist software — like Coolset’s EUDR solution — to structure and automate this.

Run your risk assessments

For each product from standard- or high-risk countries, carry out a risk assessment using the criteria in Article 10. This should cover country-level deforestation data, supply chain complexity, product-specific risk, and legality indicators. Document your conclusions.

Address any non-negligible risks

If your assessment identifies non-negligible risk, you must implement mitigation measures under Article 11 before placing the product on the market. Common measures include third-party audits, requesting additional supplier documentation, or switching to alternative sources.

Phase 3: DDS preparation and IS registration (Q3–Q4 2026)

With data collected and risks assessed, you can move to submission preparation.

Register in the EUDR Information System

All operators and non-SME downstream operators must register in the EUDR Information System. Registration opened in November 2024. The IS was upgraded following the December 2025 legislative revision, and the rules governing it were formalised via Implementing Regulation (EU) 2026/1565, adopted 13 July 2026, which introduced simplified declarations for micro and small primary operators (Article 4a), statement grouping (Article 8a), and a single-account requirement. Test your system access and workflows using the training environment.

Prepare your DDS templates

Build out your Due Diligence Statement templates. Each DDS must include: operator details, product description (HS code, commodity, quantity), country of production, geolocation of all plots, production dates, legality documentation references, and a compliance declaration. Review the required fields against your data collection to identify gaps early.

Run test submissions

Use the EUDR IS training environment to run test DDS submissions with real supplier data before enforcement begins. Check for formatting errors, incomplete coordinates, and missing documentation. This is the step most companies underinvest in and regret.

Phase 4: Go-live and ongoing compliance (from 30 December 2026)

From the application date, every shipment of in-scope products must be covered by a valid DDS before it enters or leaves the EU market.

Submit DDS for every shipment

From 30 December 2026 (or 30 June 2027 for small and micro operators), operators must submit a DDS to the EU Information System before each shipment is placed on the market or exported. Downstream operators and traders must collect and retain DDS reference numbers from their upstream suppliers. Non-SMEs must be registered in the IS.

Maintain your due diligence system

Your due diligence system must be reviewed at least annually. Update it whenever sourcing regions, supplier relationships, or country risk classifications change. Keep all documentation for at least five years and be ready to provide it to competent authorities on request.

Monitor for updates

The EUDR regulatory landscape will continue to evolve. Keep an eye on updates to the country risk classification, the Delegated Act on product scope (adopted 13 July 2026, not yet in force pending Parliament and Council scrutiny), and guidance documents published by the Commission. The Guidance Document (3rd edition) published 4 May 2026 provides important operational clarifications on due diligence obligations, particularly for low-risk sourcing.

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How software supports your EUDR timeline

Meeting EUDR deadlines at scale requires more than a project plan. Companies that manage compliance manually — through spreadsheets and email chains — consistently hit data gaps, miss supplier responses, and struggle to generate DDS submissions quickly enough.

Specialist compliance software like Coolset automates the data collection process, structures supplier outreach, links purchase orders to due diligence records, and generates DDS submissions directly in the required EU format. For companies with complex supply chains or high shipment volumes, this is often the only practical way to stay on track.

See Coolset’s EUDR module in action. Request a demo today.

June 2026 update: Confirmed dates and Information System timeline

The application dates referenced throughout this article have been revised since the original publication. Under Regulation (EU) 2025/2650, adopted on 19 December 2025 and published in the Official Journal on 23 December 2025, the binding application dates are: 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small operators on non-timber products. Micro and small operators already covered by the EU Timber Regulation (Regulation (EU) No 995/2010) must comply by 30 December 2026.

Information System timeline. The EUDR Information System was temporarily closed to integrate changes required by the December 2025 legislative revision. On 13 July 2026, the Commission adopted Implementing Regulation (EU) 2026/1565, formalising the new features: simplified declaration submission for micro and small primary operators (Article 4a), registration of new roles (downstream operators, micro/small primary operators), voluntary grouping of DDS or declaration reference numbers (Article 8a), a single registered account per user, and updated API specifications for bulk submissions. The system no longer depends on TRACES, and the Commission must publish contingency arrangements by 30 December 2026 for outages longer than 60 minutes. Companies should use the run-up to the December 2026 application date to test submissions under the new rules.

New compliance support tools. The Commission plans to launch two repositories before the December 2026 application date: one listing relevant legislation of countries of production (supporting Article 9(1)(h) legality checks), and one listing certification schemes applicable to EUDR-covered commodities. These will be hosted on dedicated websites and can be used by operators and competent authorities as reference sources during the due diligence process.

FAQ — EUDR compliance timeline

1. What is the EUDR compliance deadline?

Under Regulation (EU) 2025/2650, large and medium operators and traders must comply from 30 December 2026. Micro and small operators (non-timber products) have until 30 June 2027. Micro and small operators already covered by the EU Timber Regulation follow the 30 December 2026 date.

2. When should I start EUDR compliance preparations?

Now. The longest lead-time items in EUDR compliance are supplier data collection and building your due diligence system. Both take months. Companies that start in Q3 2026 typically face serious time pressure before the December deadline.

3. What happens if I miss the EUDR deadline?

From the application date, non-compliant products can be blocked at customs, seized from the market, and the responsible operator fined up to 4% of annual EU turnover. There is no official grace period.

4. Do I need to review my due diligence system every year?

Yes. Article 12 of the EUDR requires operators to review their due diligence system at least once a year to ensure it remains effective. You should also update it whenever you become aware of new developments that could affect the system’s aims, such as changes in sourcing regions, supply chain structures, or country risk classifications. All updates must be recorded and records kept for five years.

The review should verify that your procedures for data collection, risk assessment, and mitigation are being followed correctly, that controls are effective, and that the system continues to meet the required outcome: evidence of consistent compliance. Compliance is not a one-time exercise — it is legal, 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.

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