‍

Introduction

The EU Deforestation Regulation (EUDR) is a central part of the EU Green Deal and aims to prevent products linked to deforestation from entering the EU market. It applies to commodities like cattle, palm oil, soy, coffee, cocoa, rubber, and wood, and extends to many derived products. Businesses must prove that these goods are deforestation-free (no deforestation after 31 December 2020) and legally produced at origin.

EUDR formally entered into force on 29 June 2023. Originally, the compliance deadline for large and medium-sized enterprises was set for 30 December 2024, with small and micro-enterprises granted until 30 June 2025. However, the EUDR has since been subject to a 12-month delay. This article outlines what changed, what didn’t, and how compliance teams should act to meet the revised deadlines without sacrificing quality or compliance assurance.

What changed in the EUDR timeline?

The EUDR was originally scheduled to become applicable on 30 December 2024 for Large and Medium companies, and 30 June 2025 for Small and Micro. However, in late 2024, the EU Parliament and the Council agreed to the Commission’s proposed delay of the EUDR’s application. The approval of the Commission's proposal thus grants companies an additional 12-month phasing-in period, which they can use to prepare for the EUDR.

Given the novelty of the EUDR, the variety of international stakeholders involved, and the data-collection requirements, it has been openly welcomed by many. The Commission hopes the extra time will help to ensure proper and effective implementation of the EUDR, whilst preserving its integrity. The smooth adoption of the EUDR is likely to signal the future success of the regulation.

{{custom-cta}}

What are the new deadlines?

For companies of all size, the deadline for complying with the EUDR has been delayed:

• Large and Medium companies: 30 December 2025 – From this date, all large and medium-sized companies dealing in EUDR-regulated commodities must fully comply. Any non-compliant products will be barred from the EU market or export, and authorities can enforce penalties. 

• Small and Micro companies: 30 June 2026 – From this date, the EUDR requirements kick in for small and micro companies. These smaller firms get an extra six months to prepare, recognizing their more limited resources.

These new deadlines have been approved by the EU Parliament and Council, and are in force.

Who does the delay apply to?

The EUDR distinguishes between two roles - operators and traders - and both are impacted by the new timeline. 

An operator is any company (EU or non-EU) that places a regulated product on the EU market or exports it from the EU for the first time. In EUDR terms, an operator is any person or company who, “in the course of a commercial activity, places relevant products on the EU market or exports them”. 

This means that if your company is the first to introduce a regulated commodity or product (in HS codes as defined in Annex I) into the EU market, or to export it out of the EU, you are considered an operator under the regulation.

A trader is a company that makes available in-scope products in the EU market after they have already been placed on the market by someone else. Put simply, if you buy and sell regulated commodities within the EU (without being the first importer, producer, exporter or manufacturer), you are a trader. 

Operators and traders exist in a range of sizes, and the delays apply to them all. To better understand specific requirements for SMEs under the EUDR, have a look at the EUDR reporting guide for SMEs.

What hasn’t changed

While the timeline has shifted, all core EUDR requirements and definitions remain unchanged. Companies should stay clear on what the regulation entails. 

Shipment level due diligence

EUDR compliance works on a per shipment basis. For every shipment of in-scope commodities, operators must gather required data, conduct a risk assessment (unless exempted due to low-risk origin), and prepare a due diligence statement.

Deforestation cut-off date

The cutoff of 31 December 2020 for deforestation is fixed in the regulation. This means products are only considered “deforestation-free” if the land was not subject to deforestation after that date.

Scope of commodities and products 

The list of regulated commodities is the same seven as originally listed: cattle (beef and leather), cocoa, coffee, palm oil, soy, rubber, and wood, along with their many derived products listed by CN code in Annex I. No commodities were added or removed.

Due diligence system components

EUDR lays out specific information that must be collected: e.g. geo-location coordinates of production plots, dates of production, quantities, supplier identities, and documents proving compliance with relevant laws (land rights, permits, etc.). Companies also must perform a risk assessment (if not sourcing from a low-risk country) of deforestation or degradation and take mitigation steps if risk is more than negligible. None of these obligations have been relaxed.

In short, the EUDR’s goals and expectations are unchanged. By 30 December 2025 (for Large and Medium companies), and 30 June 2026 (for Small and Micro), companies must be able to demonstrate deforestation- and illegality-free supply chains for the covered commodities.

What you should do with the extra time

With an additional 12 months on the clock, companies have a valuable window to proactively strengthen their EUDR compliance readiness. The steps taken during this time period will put your company in a strong position to be compliant with EUDR, and avoid any delays or fines that may accompany non-compliance. 

Engage and onboard suppliers now

Don’t wait until a few months before the deadline to start gathering data from your suppliers. Use this transition period to reach out up the supply chain - especially to farmers, producers, or exporters in origin countries - and explain the information you will need from them (GPS coordinates, proof of legality, etc.). 

Early engagement is critical: suppliers may be at very different stages of preparedness, so the sooner you identify gaps, the more time you have to bridge them. The news of the delay could be a great ‘trigger’ to kick-start conversations with suppliers that might have stalled. Encourage suppliers to start mapping their own supply network and collecting documents. Consider providing training or templates if needed. By building these relationships and data-sharing processes now, you’ll avoid a last-minute scramble that could lead to blocked shipments when the law comes into force.

Inventory your products and match them to HS codes

A practical exercise to do during this phase is to list all commodities and products your company deals in, and check which ones fall under EUDR’s scope. The EUDR not only applies to the seven raw commodities, but also to relevant derived products. 

For each in-scope item, find the corresponding HS code and see if it is listed in Annex I of the regulation. By doing this exercise, you ensure that no relevant product is overlooked, and you don’t face any surprises further down the line. Mapping your product catalogue to the EUDR list will clarify exactly which supply chains require due diligence, and allow you to get a head start. 

Get familiar with the EU’s reporting system (TRACES)

The European Commission has launched the EUDR Information System on the existing TRACES platform, which is where due diligence statements must be submitted. There is a production (live) system and a training platform for practice. Companies should register an account and explore the test environment well before the deadline. 

Learn how to create a due diligence statement (DDS), what fields and attachments are required, and how to obtain the unique DDS reference number that accompanies each shipment. By practicing in the TRACES test environment, you can work out technical issues and get your team comfortable with the interface. When the EUDR comes into force, you will be able to quickly submit a DDS for each shipment.  

Integrate EUDR data into your operations and IT system

Use this extra year to build robust internal processes for EUDR compliance. This might include using a software tool to store all required supply chain data (geo-coordinates, supplier docs, etc.), linking it with your procurement or ERP systems so that every incoming order is flagged if it’s in scope. 

Many companies are developing data templates and checklists for suppliers, updating contracts to include EUDR clauses, and creating Standard Operating Procedures for compliance checks. For example, run a pilot trace on one high-risk supply chain – collect all the data and generate a dummy DDS – to see where there are bottlenecks or missing info. This dry run can highlight if you need new tools or more resources.

How Coolset helps you stay on track

Coolset’s platform is designed to simplify EUDR compliance for companies of all sizes. It enables businesses to:

• Automate DDS generation: Pull supplier data into pre-configured DDS templates. Save time and reduce error.
• Validate origin data: Flag missing GPS coordinates, incomplete documents, or mismatches.
• Benchmark risk: Incorporate EU country risk scores to scale due diligence efforts based on sourcing location.
• Audit-proof recordkeeping: Maintain all DDS, supplier documents, and risk assessments in a secure archive.
• Integrate with ERP tools: Pull product data and sourcing details directly from procurement or supply systems.

Coolset’s tools are pre-configured to support EUDR documentation requirements and designed for ESG or compliance teams that need to move fast. 

FAQ: EUDR timeline updates

What is the EUDR transition period? 

The transition period refers to the window between the regulation’s entry into force (29 June 2023) and the application deadlines (30 December 2025 or 30 June 2026, depending on company size). During this time, companies should prepare for compliance but are not yet legally required to submit DDS.

What is the EUDR implementation timeline?

• Regulation in force: 29 June 2023
• Enforcement for large/medium firms: 30 December 2025
• Enforcement for small/micro firms: 30 June 2026

What is the EUDR cut-off date?

All products must originate from land not deforested after 31 December 2020. This applies globally and cannot be changed or extended.

The 12-month delay for EUDR enforcement gives companies a valuable window to build internal capacity and to reduce risk of non-compliance. However, EUDR obligations remain firm and enforcement is expected to be robust once the deadlines arrive. By acting now companies can avoid disruption and delays later on. Explore Coolset’s EUDR resources, or reach out to the team for more information. 

‍