Latest update: November 27, 12:00 CET

Understanding the latest EUDR timeline and what it means for your business

The EU Deforestation Regulation (EUDR) is still legally set to apply from 30 December 2025, but the latest Parliament vote signals that enforcement is likely to be postponed. On 17 November 2025, the Council adopted its official position proposing a full one‑year delay for large and medium operators to 30 December 2026, and a further extension for small and micro primary operators to 30 June 2027 (non-timber).

On 26 November 2025, the European Parliament voted to support this delay, along with a mandated simplification review by April 2026. With Parliament now aligned with the Council on the core direction of change, the three institutions will move into trilogue negotiations to agree on the final legal text. Read our in depth summary of the Parliament vote here

Until that process concludes and the final text is published in the Official Journal of the EU, the original 30 December 2025 deadline remains binding. A one‑year delay is likely, but not confirmed until the final law is formally adopted.

What happens next?:

• 26 November 2025: The European Parliament votes in favour of a 12-month delay to the EUDR and a simplification review by April 2026.
• December 2025: Trilogues begin between Parliament, Council, and Commission. The goal is to finalize the amendment before year-end. A “stop-the-clock” move, like with CSRD, remains possible if talks stall.
• Early 2026: If a compromise is reached, the joint text is reviewed and finalized.
• Early/Mid-2026: Once adopted by both institutions, the amendment is published in the Official Journal and becomes legally binding.

In this article, we explain what’s changed, what remains the same, and what compliance teams should do now to stay aligned with the evolving EUDR timeline.

What is the legally binding EUDR timeline now?

The EU Deforestation Regulation (EUDR) becomes legally binding from 30 December 2025 for all operators and traders. However, the European Council have published an official position on a full one-year delay for large and medium operators to 30 December 2026, plus a further 6 month delay for SMEs to 30 June 2027. This move was later accepted in the Parliament's vote on 26 November.

Below is an overview of the European Parliament’s position on the EUDR timeline:

Coolset has summarised the Parliament vote in this article.

How did the EUDR timeline evolve from delay rumours to now?

The EUDR timeline has shifted several times. Originally set for December 2024, enforcement was delayed to December 2025. In late 2025, the Commission proposed a grace period, but the Council instead backed a full one-year delay. On 26 November, the Parliament supported this approach, aligning all three institutions and triggering trilogue negotiations.

Here’s the detailed timeline of EUDR changes, accepted and proposed delays:

🔹 26 November 2025 - Parliament votes in favor of a delay and simplification review

A majority in the European Parliament voted to support the Council’s proposed one-year delay to the EUDR:

• New enforcement dates: 30 December 2026 for large and medium operators, and 30 June 2027 for small and micro operators (non-timber)
• A legally required simplification review by 30 April 2026 focused on small and micro primary operators

What happens next: Parliament will submit its position as a first reading, and trilogue negotiations with the Council and Commission will begin.

🔹 17 November 2025 - Council publishes its official position

The Council has proposed:

• A one-year delay for large and medium operators to 30 December, 2026 and for small and micro operators to 30 June, 2027
• Introducing a legally required simplification review by 30 April 2026
• What now: Parliament votes on whether to endorse the proposal on 26 November

Read the Council's full summary here.

🔹 21 October 2025 - Commission proposes enforcement plan in a surprising turn

In a shift from the tone from Commissioner Roswall’s letter (see below), which proposed one-year delay in EUDR enforcement, The European Commission's proposal maintained the original December 2025 deadline for most large and medium-sized operators, suggesting to:

• Keep 30 December 2025 as the enforcement date for large and medium-sized operators and traders.
• Introduce a grace period from January to June 2026, during which competent authorities would prioritize support over penalties.
• Grant small and micro enterprises an additional six months, moving their compliance deadline to 30 December 2026.
• Introduce new roles and responsibilities, such as small and micro primary operators and downstream operators, with the aim of simplifying compliance and reducing administrative burden for smaller actors.

🔹 Early October 2025 - Debate and industry reactions

Following Commissioner Roswall's letter, EU debate intensified. Several Member States backed a delay, citing competitiveness and administrative burden. The European People’s Party supported postponement as a way to correct regulatory flaws and protect SMEs. In contrast, the Socialists & Democrats criticized the move, calling the delay a concession to lobbying pressure that risks weakening enforcement. Meanwhile, in a separate letter from major companies including Nestlé, Mars Wrigley and Ferrero, they urged the European Commission not to delay the EUDR and reaffirmed their commitment to the December 2025 deadline.

🔹 23 September 2025 - The Roswall letter proposes another one-year delay

In a letter to the European Parliament and the Council, Commissioner Jessika Roswall recommended postponing EUDR enforcement until December 2026. The proposal cited delays in the EU’s TRACES IT system and uneven readiness across Member States as key reasons for deferring the enforcement timeline.The letter was non-binding and intended to ease growing political pressure around the regulation’s rollout.

🔹October 2024 - The first 1-year postponement accepted

In 2024, the enforcement timeline for the EUDR was moved from December 2024 to December 2025, citing system and enforcement readiness concerns.

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What has to happen for the EUDR deadline to officially change?

The EUDR deadline or deadlines, only change after the European Union goes through its full legislative process. Firstly, the proposal must be passed by the European Parliament and the Council, and formal adoption and publication in the Official Journal of the EU.

How amendments become law:

1. Commission proposal submission
   The European Commission submits a formal amendment to the regulation.

2. Parliament review and vote
   Parliament committees review the proposal and may introduce amendments. A full plenary vote will follow.
   

• If approved without changes, the text proceeds to the Council.
• If amendments are made, and the Council disagrees, a trilogue may follow.
  

3. Trilogue negotiations (if needed)
   The Commission, Parliament, and Council may enter trilogue negotiations to agree on a joint text.
   

• If successful, the agreed text returns to both institutions for formal approval.
  

4. Council deliberation and vote
   The Council reviews and votes on the final proposal or trilogue outcome. Legal review and negotiation may occur at this stage.
   
   
5. Adoption and legal effect
   Once both Parliament and Council approve the text, it is published in the Official Journal of the EU. The amendment becomes legally binding only after publication.

The Council’s position published on 17 November 2025 and the European Parliament’s vote on 26 November both support a delay, but these do not change the law until a final text is agreed in trilogue, formally adopted, and published in the Official Journal.

What does the European Parliament's EUDR vote mean for different operators?

The European Commission's October proposal introduced new role categories, which were expanded in the Council’s position and these have now been endorsed by the European Parliament.

Key proposals by role (updated after Parliament vote):

1. Large and medium operators: Deadline delayed, core obligations unchanged
Operators with >50 employees and ≥€10 million turnover must still collect supplier data, conduct risk assessments, and submit due diligence statements (DDS) in TRACES. The new proposed enforcement date is 30 December 2026, with no grace period. Full due diligence applies regardless of country risk level.

2. Small and micro primary operators: New simplified declaration
Small and micro primary operators in low-risk countries who place products on the market themselves will not submit full DDS. Instead, they will file a one-time simplified declaration, which must be updated only in case of major changes. They can use postal addresses instead of geolocation. The new enforcement date is 30 June 2027.

3. Downstream operators: Scope narrowed, obligations simplified
Downstream operators are now clearly defined as businesses that buy from operators and place those products on the market.

• Only the first downstream operator must retain and pass on DDS and traceability reference numbers.
• Downstream operators buying from other downstream operators are now excluded from EUDR obligations.
  Exporting downstream operators are exempt from customs DDS requirements.
  

4. Non-SME traders: Follow simplified downstream rules
Larger traders (non-SMEs) who do not directly import products no longer need to submit DDS. They must follow the same obligations as downstream operators: retain and pass on DDS reference numbers, without having to create or validate new DDS.

5. SME traders: Minimal burden maintained
Small and medium-sized traders continue to collect and retain DDS references but are not required to submit them. No new obligations apply.

For a practical breakdown of the latest roles and responsibilities, check this overview.

Definitions of EUDR roles:

Large and medium operators are defined as companies above small and medium enterprise (SME) thresholds (typically >50 employees and >€10 million turnover) that place materials on the EU market, either through production or import, or export materials from the EU.

Example: A global cocoa importer sourcing from Côte d’Ivoire must geolocate farm plots, assess deforestation risk, and submit a DDS for every shipment placed on the EU market.

Small and micro primary operators are small producers or farmers who grow, harvest, or raise relevant products themselves and are established in low-risk countries as defined under the EU benchmarking system.

Following the Parliament’s recent vote, small and micro primary operators would no longer need to submit a full DDS. Instead, they would provide a one-time simplified declaration to be updated only if major changes occur, but this will only apply if adopted in the final legal text.

Example: A smallholder in Germany harvesting timber submits a simplified declaration once. That declaration applies to all future shipments unless their production circumstances significantly change.

Downstream operators are any natural or legal person who, in the course of a commercial activity, places on the EU market or exports relevant products to the EU that are already covered by a due diligence statement or a simplified declaration. They may place these products on the EU market, but they are not the ones conducting new due diligence because all inputs have already been verified upstream.

The Parliament’s vote adopted the following conditions:

• Only downstream operators who buy directly from an operator must record and pass on DDS reference numbers.
• Downstream operators who buy from other downstream actors are now excluded from EUDR obligations.
  Downstream operators exporting products are exempt from customs DDS requirements.

Example: A chocolate manufacturer sourcing cocoa directly from an operator must retain and transmit DDS references. If sourcing from a downstream trader, the manufacturer is no longer in scope.

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How should companies prepare for EUDR compliance now?

To be ready ahead of enforcement, companies typically begin by mapping supply chains, collecting supplier data, assessing risks, and building TRACES-compatible due diligence workflows.

6-step readiness playbook:

1. Confirm scope and roles - Identify commodities and determine if you’re an operator or trader.
2. Map supply chains - Trace origin and supplier relationships.
3. Collect supplier data - Coordinates, production dates, land rights documentation.
4. Assess and mitigate risk - Use a standard risk framework.
5. Draft DDS files - Test TRACES workflows in the EU’s test environment.
6. Align contracts - Add EUDR clauses and data-sharing terms.

Clients use Coolset to centralize supplier data, manage version control, and automatically generate audit-ready due diligence statements (DDS) in TRACES-compatible formats.

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What are the current EUDR risk levels and enforcement expectations?

All countries are currently classified as standard risk under the EUDR. The European Parliament rejected the Commission’s proposed benchmarking act, meaning no country currently benefits from any ‘low-risk’ shortcuts. As a result, all due diligence obligations apply equally, including geolocation, legality documentation, and risk assessments.

According to Parliament’s vote, core obligations would apply from 30 December 2026 (or 30 June 2027 for non-timber small and micro primary operators). The vote also requires the Commission to review the regulation for further simplifications in April 2026.These changes are not yet law and will depend on trilogue negotiations.

As the revised dates are not yet legally in force, operators should prepare for both the current and proposed timelines. Companies should continue building due diligence workflows, collecting supplier data, and testing TRACES compatibility.

What happens next in Brussels?

Now Commission, Council and Parliament will move into trilogues (a discussion of three parties) where negotiators work toward a single agreed text. Given that the Council position was driven by Germany and supported by France, and considering the EPP’s deregulatory push, it is highly likely the outcome will confirm the delayed compliance dates and mandate a simplification review by April 2026, with further adjustments possible depending on the review’s findings.

Updated Expected timeline:

• 26 November 2025: The European Parliament votes in favour of a 12-month delay to the EUDR and a simplification review by April 2026.
• December 2025: Trilogues begin between Parliament, Council, and Commission. The goal is to finalize the amendment before year-end. A “stop-the-clock” move, like with CSRD, remains possible if talks stall.
• Early 2026: If a compromise is reached, the joint text is reviewed and finalized.
• Early/Mid-2026: Once adopted by both institutions, the amendment is published in the Official Journal and becomes legally binding.
  

FAQ – Common questions about the EUDR timeline and enforcement

Will the EUDR be delayed to 2026?

The EUDR has not yet been officially delayed - the 30 December 2025 deadline remains legally binding until a final legal text is adopted and published. However, both the Council and the European Parliament now support a full one-year delay for large and medium operators (to 30 December 2026), and a further delay for small and micro operators (to 30 June 2027).

What is the EUDR enforcement grace period?

The grace period (Jan-June 2026) was part of the Commission’s October proposal. The Council and Parliament have replaced this with a full enforcement delay. If the current proposals are adopted, EUDR will apply in full from the new dates, and the grace period will not be part of the final regulation.

Do small operators have different deadlines?

Yes, both the Council and Parliament now support extending the EUDR deadline for small and micro operators to 30 June 2027 (non-timber products), six months after the proposed new date for large and medium operators (30 December 2026). Parliament also backed a one-time simplified declaration for small and micro primary operators and supported a planned simplification review in April 2026.

Has the EUDR risk level changed?

No. All imports are currently subject to standard risk under the EUDR. The EU Parliament rejected the Commission’s proposed benchmarking system, so no country currently benefits from a low-risk designation.