What’s actually changing with the EUDR timeline, and why it matters

The European Union Deforestation Regulation (EUDR) deadline has not yet changed. The current enforcement date of 30 December 2025 remains legally binding. However, a recent letter from the European Commission suggests a possible delay, creating an uncertain timeline.

Even if enforcement moves to 2026, the requirements don’t disappear. Traceability, due diligence, and reporting will still be core obligations. This article outlines what has happened, what needs to happen for a delay to become official, and how companies should prepare regardless of shifting timelines.

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Has the EUDR deadline officially changed?

The EUDR timeline has not changed, the enforcement date remains 30 December 2025. No formal delay has been adopted, meaning the regulation is still set to apply as planned unless amended through the EU’s legislative process.

It’s worth recalling what led to this moment. Several concerns came up repeatedly in Brussels and during the recent EUDR webinar:

• EU IT system not ready for enforcement
  TRACES NT, the EU’s due diligence platform, was flagged in Commissioner Roswall’s letter as not yet capable of managing the volume of incoming documentation.
  
  
• Member States aren’t aligned on readiness
  Some countries have advanced national systems in place, while others are still building theirs from scratch, creating risks of fragmented and inconsistent enforcement.
  
  
• Suppliers lack clarity on required documentation
  In producing countries, many suppliers have limited guidance on what documentation is needed. This uncertainty could cause bottlenecks once enforcement begins.
  
  
• Trade friction concerns for smallholder-heavy supply chains
  Several Member States warned that immediate enforcement could disrupt trade, particularly for commodities like cocoa and coffee, where supply chains depend heavily on smallholders.

For now, the safest approach is to work toward December 2025 while monitoring developments in Brussels.

What is the Roswall letter and how much weight does it carry?

The Roswall letter is a non-binding recommendation from EU Environment Commissioner Jessika Roswall, sent on 29 September 2025. It suggests pushing the EUDR enforcement deadline for large and medium-sized companies to 30 December 2026, with smaller businesses following six months later.

The letter points to two main concerns: delays in the EU TRACES system and uneven enforcement readiness across Member States. While it reflects growing political pressure to slow the rollout, it does not carry legal weight. The current EUDR deadline of 30 December 2025 remains in force unless the European Commission formally proposes a change and both Parliament and Council approve it.

For a full breakdown, see our article on the EUDR postponement letter.

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What needs to happen for the delay to become official?

For the EUDR deadline to be legally postponed, the European Union must go through its full legislative process. A letter alone cannot change the law. The following steps need to happen:

1. Commission proposal submission
   The EU Commission must draft and submit a formal proposal to amend the enforcement dates in the regulation. This moves the idea from a political signal into the legislative pipeline.
   
   
2. Parliament and Council deliberation
   Both the European Parliament and the Council of the European Union must review and agree to the proposal under the ordinary legislative procedure. This includes committee discussions, potential amendments, and political negotiations.
   
   
3. Final amendment adoption and publication
   Once both institutions approve, the amendment must be formally adopted and published in the Official Journal of the European Union. Only then does the new timeline become legally binding.

Delays could occur at multiple stages of the legislative process. The Commission may take additional time to draft its proposal, Parliament could introduce conditions or contest changes, and Council negotiations may reveal disagreement among Member States on whether to postpone or enforce the original deadline.

However, until all three steps are completed, the 30 December 2025 deadline remains in force.

When will the European Parliament and Council decide on the EUDR delay?

Timing of EUDR depends on how quickly the EU Commission acts and how the legislative bodies prioritize the amendment. At this stage, three scenarios are possible:

1. No proposal submitted: It’s still possible, although unlikely, that the EU Commission opts not to propose any changes, in which case the current EUDR timeline stays in effect. Clarity on this is expected within the next two weeks.
2. Fast-track (late 2025): If the EU Commission submits a proposal and it is prioritized soon, Parliament and Council could approve before the end of the year.
3. Moderate pace (early 2026): A more likely scenario is that additional debate would push approval into Q1 2026. This would create a short period of uncertainty where the official deadline is still December 2025, even though a delay is under active discussion.
4. Extended debate (mid-2026 or later): If there is resistance from some Member States or Parliament committees, negotiations could spill well into mid-2026.

For compliance teams, the official deadline remains unchanged until both EU Parliament and Council adopt an amendment. While monitoring the EU legislative process is essential, December 2025 should remain the working assumption.

What is the likely new timeline if the EUDR delay passes?

If the EUDR delay is approved, the most likely outcome is a 12-month extension of the current deadlines:

• Large and medium-sized companies: new enforcement date of 30 December 2026.
  
  
• Small and medium-sized enterprises (SMEs): new enforcement date of 30 June 2027.

While Council environment ministers have shown openness to a delay, Parliament remains a key variable. The European People’s Party (EPP), which is strongly in favor of postponing, has a majority together with other political blocs to its political right.

For companies, that would mean an additional year to build due diligence systems, test supplier data collection, and prepare for audits. But until the amendment is formally adopted, 30 December 2025 is still the only binding date.

Step-by-step – How to prepare for EUDR now while the deadline is uncertain

To prepare for EUDR compliance, businesses should begin collecting supplier data, building internal due diligence workflows, and testing systems, regardless of whether enforcement starts in 2025 or 2026. The compliance tasks remain the same, businesses that use this time wisely will be better positioned when the law takes effect.

1. Continue supplier data collection

Start with the hard requirements: collecting geolocation data, production dates, and legality documentation from suppliers. Even if deadlines shift, these data points will be required. Early collection helps flag suppliers that cannot provide accurate information.

• Many producer countries and sectors are already flagging smallholder risk under EUDR. In Indonesia, officials warned that farmers may struggle to meet geolocation and documentation demands. At the same time, cocoa supply chains also face traceability complexity.
  
  
• For practical guidance on what to request, see Coolset’s EUDR due diligence guide.
  
  

2. Build internal DDS workflows (TRACES-compatible)

The Commission’s EU TRACES platform will be the only official channel for submitting due diligence statements. Companies should design workflows that align with the system’s requirements, not only for submission, but also for creating an internal audit trail.

• A modular workflow allows data to be updated as suppliers provide corrections.
  
  
• Supplier versioning is especially important: if data changes mid-year, companies must demonstrate which version was used in each statement.
  
  

3. Run mock audits or risk assessments for high-risk goods

Testing systems before they go live reduces the chance of disruption. Running a mock audit can reveal whether supplier data is complete and whether risk assessments are defensible.

• This is most critical in supply chains that rely heavily on smallholders, such as cocoa and palm oil, where fragmented production and limited documentation make due diligence most challenging.
  
  

4. Monitor the EU lawmaking calendar

Finally, keep an eye on Brussels. The only way a delay becomes binding is through a formal amendment, and businesses should track when the Commission publishes its proposal and how Parliament and Council respond.

• Coolset regularly publishes updates in our EUDR Academy hub.
  
  
• Companies should also monitor the EU Parliament legislative observatory for official updates on the file.
  
  

The message is consistent: don’t pause compliance. Use the current uncertainty to strengthen systems, test processes, and resolve supplier gaps ahead of time.

What data should businesses start collecting now?

To meet EUDR compliance requirements, businesses should start collecting geolocation data, production timelines, legal documentation, and supply chain traceability records, regardless of the final enforcement date. This reduces last-minute scrambling and highlights suppliers who cannot yet meet requirements.

Here is a practical checklist of what every compliance team should be collecting:

✓ Collect geolocation coordinates

Obtain precise farm or plot coordinates for all EUDR-covered commodities. Data should be in a standardized format (latitude/longitude) and link clearly to production areas. Without geolocation, due diligence statements (DDS) cannot be validated.

✓ Collect production dates

Gather planting and harvesting dates, or equivalent production records, to demonstrate when commodities were produced. This helps confirm that goods do not originate from land deforested after the regulation’s cut-off date of 31 December 2020.

✓ Request legal compliance documents

Ask suppliers for clear evidence of land-use rights, harvesting permits, or concession licenses, depending on the commodity. These documents must come from recognized authorities and should be verifiable. (See our EUDR due diligence guide for examples.)

✓ Gather supplier traceability information

Request supporting documents that link commodities through the supply chain, such as invoices, transport records, or mill certificates. Strong traceability ensures that the geolocation data connects seamlessly from farm to first placement on the EU market.

✓ Draft DDS in TRACES-compatible formats

Begin drafting DDS files in TRACES-compatible formats. Running early submissions internally can help confirm whether all fields are complete and highlight gaps before enforcement begins.

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Businesses that start collecting this data now will not only reduce compliance risk but also build trust with suppliers and regulators. The extra lead time allows for corrections, version control, and training before the system goes live.

How software helps companies stay EUDR-ready regardless of timeline

Staying prepared for EUDR means working with tools that can adapt as requirements evolve. Effective compliance software should support four core capabilities that make preparation more reliable, regardless of how the timeline develops.

Easier supplier data collection

Collecting the right information is one of the hardest parts of EUDR compliance. Companies must track things like:

• Geolocation coordinates
  
  
• Land use documents
  
  
• Production dates
  
  

Doing this manually (through email, spreadsheets, or calls) is slow and messy. Software makes it easier. It stores all data in one place and connects it to specific products or shipments. This means you don’t have to start over each time the rules change. If the EU updates its templates, new fields can be added without rebuilding your entire process.

Keeping a clear record of changes

Supplier data is never static. A farmer might update their plot coordinates. A distributor might correct a land use certificate. Without proper tracking, these changes can be hard to follow, and harder to explain.

Good software logs every update and shows who changed what, and when. This version history matters. If your report is ever questioned, you’ll be able to show exactly how the data evolved over time.

Transparent risk alerts

EUDR isn’t just about checking boxes. If a supplier is high risk, companies need to show why - and what they did in response.

Strong compliance tools don’t just raise alerts. They show which data triggered the risk, explain the issue, and let you log your follow-up. This helps internal teams make better decisions. It also creates a clear trail for authorities and auditors.

Audit-ready TRACES files

All EUDR reports must be submitted in the EU’s TRACES NT system. Each report, called a Due Diligence Statement (DDS), must include supporting documents and follow a strict format.

Software that creates DDS files in the right structure, automatically linked to your data and audit trail, saves time and reduces errors. It also means every report is backed by solid documentation.

Implementing a system that can accommodate shifting timelines helps reduce last-minute pressure and keeps compliance efforts on course. While enforcement dates may change, the underlying requirements remain. For further guidance, see our EUDR page and due diligence guide.

For more detail, see our EUDR due diligence guide.

FAQs – Common questions about the EUDR delay process

Has the EUDR deadline been officially postponed?

No, the enforcement date of 30 December 2025 remains binding law until an official amendment is passed by the EU Parliament and Council.

What’s the difference between a letter and law in EU policymaking?

A letter shows political intent but has no legal effect. The law only changes once an amendment is formally adopted.

What are the legal steps needed for the delay to take effect?

The Commission must submit a proposal. Parliament and Council then debate and approve it under the ordinary legislative process. The amendment becomes binding once published in the EU’s Official Journal.

What happens if Parliament rejects the delay?

The 30 December 2025 enforcement date stands. Companies would need to comply on schedule, regardless of prior discussions about postponement.

Should we keep preparing even if the deadline shifts?

Yes. The regulation’s requirements will not change, only the timing. Businesses that continue collecting data and building processes now will be better positioned when enforcement begins.