No general EUDR delay: What the European Commission's latest parlimentary leaks signal

November 3, 2025
2
min read

Disclaimer: Latest EUDR developments

On 21 October, the European Commission proposed targeted changes to the EU Deforestation Regulation (EUDR). These adjustments aim to make the rollout smoother without changing the regulation’s overall goals.

Key points from the proposal:

  • The 30 December 2025 compliance deadline for large and medium operators remains unchanged.
  • Small and micro primary producers (such as farmers and foresters) may receive an extension until 30 December 2026.
  • A transition period from January to June 2026 is planned for large and medium companies, giving them time to adapt before formal checks and penalties begin.
  • New, simplified obligations are introduced for two groups: small and micro primary producers, and downstream operators (e.g. manufacturers, retailers).

We're closely monitoring the development and will update our content accordingly. In the meantime, read the full explainer here.

Key takeaways:
  • Large and medium-sized companies must still comply with EUDR by December 30, 2025 – no extension has been granted.
  • Small and micro producers in low-risk countries may benefit from a deferred deadline of December 30, 2026 and simplified reporting.
  • Coolset helps companies automate traceability, supplier data collection, and DDS submission to ensure timely EUDR compliance

The European Commission has officially proposed a series of targeted measures to make the rollout of the EU Deforestation Regulation (EUDR) smoother and more manageable. The key compliance date for large and medium-sized companies remains December 30, 2025, with inspections and enforcement beginning in mid-2026.

The proposal introduces a one-year extension and lighter reporting requirements for small and micro-producers (such as farmers and foresters) in low-risk countries. It also removes duplicate due diligence submissions for downstream actors such as manufacturers and retailers, who must still be registered in the EUDR system and submit supplier data.

These adjustments are intended to reduce administrative burden and stabilize the EU's IT system without changing the core of the regulation, ensuring full visibility and deforestation-free supply chains. The proposal will now be reviewed by the European Parliament and the Council before becoming law, so some details are still subject to change.

Important updates from the European Commission

1. No change in deadline for large and medium-sized enterprises.

Large and medium-sized enterprises that place commodities such as soy, palm oil, cocoa, beef, timber, and rubber on the EU market must still comply with the EU Deforestation Regulation (EUDR) by December 30, 2025. Inspections and enforcement checks will begin on June 30, 2026.

2. One-year deferral and lighter reporting for micro and small primary producers.

A new category, "micro and small primary operators" (such as farmers and foresters in low-risk countries), will have an extended compliance deadline until December 30, 2026. They will no longer be required to submit full due diligence declarations (DDS); instead, they will submit a one-time declaration or provide relevant data via national or recognized databases, generating a "declaration ID" that can be used throughout the supply chain.

3. Simplified obligations for downstream operators.

Manufacturers, retailers, and other downstream actors no longer need to submit their own DDS, provided the upstream importer has already done so. However, they must register in the EUDR information system and ensure traceability by collecting and transmitting due diligence reference numbers or declaration IDs.

4. Deployment focused on system stability and reduced administrative burden.

The adjustments reflect the Commission's commitment to reducing the burden on the EUDR IT system and cutting bureaucracy, while maintaining full traceability. The proposal is now being reviewed by the European Parliament and the Council, and the final regulations are expected shortly.

These updates provide clearer guidance for companies, but do not imply a general postponement or weakening of responsibility. Compliance planning must continue with focus and urgency.

What this means for companies

For large and medium-sized companies, the message is clear: EUDR compliance must continue as planned for 2025. Systems for supplier mapping, traceability systems, and due diligence documentation need to be in place by the end of that year, as inspections are set to begin in mid-2026.

The main change affects how reporting is handled in the supply chain:

  • Downstream operators, such as manufacturers and retailers, will no longer submit their own due diligence statements but must remain registered in the EUDR system and pass on reference numbers and declaration IDs to maintain full traceability.
  • Micro and small producers in low-risk countries will benefit from simplified reporting, submitting a one-time declaration or equivalent data via national databases. Larger buyers will still need to verify and integrate these records into their due diligence processes.

Collaboration with suppliers becomes essential. Every link in the chain must be able to connect their materials to a verified declaration or DDS.

In short, the Commission’s proposal offers simplification and clarity, but not more time. Companies that start now by structuring their data, engaging suppliers, and automating traceability will be best positioned to pass inspections and avoid disruption in 2026.

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What now?

The Commission's proposal will now go to the European Parliament and the Council for review and adoption. Both institutions are expected to discuss and vote on the amendments before the end of 2025.

If approved, the regulation will officially apply from:

  • 30 december 2025 for large and medium-sized companies (with inspections and enforcement from 30 June 2026)
  • 30 december 2026 for small and micro primary producers

Until the vote is finalized, companies should continue to prepare, assuming the current timelines remain in place.

The Coolset research team will continue to closely monitor developments and will share detailed updates and practical guidance after the legislative vote.

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