EUDR postponement: How companies are responding to the proposed EUDR delay

October 7, 2025
5
min read

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:
  • Most companies (91%) are continuing EUDR preparations despite the proposed one-year delay.
  • Trust in EU regulatory direction is weakening, with 69% expressing concern.
  • Coolset supports preparation now, helping teams stay ready even amid shifting signals.

Carbon accounting is the systematic measurement, monitoring, and reporting of greenhouse gas (GHG) emissions across an organization. For companies pursuing science-based targets, accurate carbon accounting is foundational because it:

  • Establishes a baseline: You can't manage what you don't measure
  • Enables target-setting: Science-based targets require a clear baseline year and methodology
  • Drives efficiency: Identifying emission hotspots enables targeted reduction strategies
  • Demonstrates progress: Regular monitoring shows whether reduction efforts are working
  • Supports compliance: CSRD and other regulations mandate accurate GHG reporting

Scope 1, 2, and 3 Emissions

The Greenhouse Gas Protocol divides emissions into three scopes:

Scope 1: Direct Emissions

Emissions from sources your company directly owns or operates. Examples include:

  • Company-owned vehicles and equipment
  • Furnaces and boilers in owned facilities
  • Chemical reactions in manufacturing processes

Scope 2: Indirect Energy Emissions

Emissions from electricity, steam, or heat your company purchases. This includes:

  • Purchased electricity for offices and facilities
  • Purchased steam or hot water
  • Purchased cooling

Scope 3: Other Indirect Emissions

All other indirect emissions in your value chain, including:

  • Employee commuting and business travel
  • Purchased goods and services
  • Waste and wastewater
  • Downstream use of sold products

Key Steps in Carbon Accounting

  1. Define organizational boundaries: Decide whether to use equity share or operational control
  2. Identify emission sources: Map all activities that generate emissions
  3. Collect activity data: Gather consumption and operational data
  4. Apply emission factors: Use IPCC or region-specific factors to convert activity data to emissions
  5. Calculate and report: Sum emissions by scope and category
  6. Verify and assure: Have calculations reviewed by internal or external auditors

Common Challenges

  • Data availability: Especially for Scope 3, data may be scattered or incomplete
  • Scope 3 complexity: Many categories, inconsistent supplier data, and estimation requirements
  • Baseline year selection: Historical data quality and consistency affect baseline year choice
  • Methodology consistency: Changes to calculation methods can make year-on-year comparisons difficult

Tools and Systems

Many organizations use specialized carbon accounting software to:

  • Automate data collection from various systems
  • Apply consistent emission factors
  • Track changes over time
  • Generate audit-ready reports
  • Support scenario modeling for reduction strategies

Conclusion

Carbon accounting is not just a compliance exercise - it's a strategic capability that enables data-driven climate action. By implementing sound accounting practices, your organization can accurately measure emissions, set credible science-based targets, and demonstrate progress toward climate goals.

Prepare for EUDR in 4 on-demand sessions

Our research team walks you through every step - from supplier engagement to submitting in TRACES.

See Coolset in action
Explore Coolset's top features and use cases.
Demo is not supported
on mobile screens
Please come back on a larger screen
to experience this demo.
This is a preview window. Click below to see the demo in a larger view.
See product tour
See product tour
See product tour
See product tour
See product tour
See product tour

↘ Instantly calculate your CBAM cost impact

Use the free calculator to estimate your Carbon Border Adjustment Mechanism costs for any imported goods. Select your product type, volume and country of origin to see projected CBAM charges and understand how upcoming EU rules will shape your import costs and savings through 2034.

↘ Check if your documentation meets PPWR requirements

This free compliance checker scans your packaging documentation and maps it against mandatory PPWR data requirements, giving you a clear view of your compliance status. Get actionable insights on documentation gaps before they become compliance issues.

Start preparing for EUDR

Get your systems ready for traceability, risk assessment and due diligence. for EUDR

Download our 2026 EUDR playbook

Based on customer case studies our team has developed a realistic timeline and planning for EUDR compliance. Access it here.

🎉 Thank you!
You will receive an email with the playbook
Oops! Something went wrong while submitting the form.

The leading ESG platform for mid-market enterprises