The EU Deforestation Regulation (EUDR) was meant to become operational at the end of 2024, then it was pushed to the end of 2025. Over the Christmas period, the EU agreed a second delay and a set of targeted changes that shift who files what, and when. The regulation is a major supply chain compliance shift, requiring companies to prove certain commodities and products are deforestation-free before placing them on the EU market. It applies to commodities such as cocoa, coffee, palm oil, soya, cattle, rubber and wood, plus a wide range of derived products.
The European Parliament adopted the agreed text in December, the Council has now signed off, and the amending regulation has been published in the Official Journal. The delay gives organisations more time, but it also extends uncertainty for compliance programmes and investment decisions across global supply chains.
What’s the latest as of January 2026?
Regulation (EU) 2025/2650 was published on 23 December 2025 and entered into force three days later.
What does not start yet is the compliance obligation for most companies. The core “operator and trader” requirements apply from 30 December 2026, and there is a further extension for certain micro and small operators until 30 June 2027.
Key dates at a glance
- 23 December 2025: Regulation (EU) 2025/2650 published in the Official Journal
- 26 December 2025: amendment enters into force (three days after publication)
- 30 December 2026: main EUDR obligations apply for most operators and traders
- 30 June 2027: extended start date for certain micro and small operators (subject to conditions in the text)
- 30 April 2026: Commission must complete a simplification review and report, with the option of a further legislative proposal
The aim of EUDR (quick reminder)
The EUDR is designed to stop products associated with deforestation or forest degradation entering (or leaving) the EU market without evidence. It covers commodities including cattle, cocoa, coffee, palm oil, rubber, soya and wood, plus a long list of derived products.
The EU itself frames the policy as significant because EU consumption has been linked to a meaningful share of global deforestation.
What actually changed in the December 2025 revision
1) The deadline moved (again)
The headline change is the extra 12 months. After the earlier one year postponement adopted in 2024 (which made the regime applicable from 30 December 2025), the new amendment pushes the main application date to 30 December 2026, with additional time for some micro and small operators.
This is not just a political statement. It is now written into the operative “application” article of the regulation.
2) A simplification review is now baked in, before implementation
By 30 April 2026, the Commission must carry out a “simplification review” and publish a report. If the Commission thinks further changes are needed, it can pair that report with a new legislative proposal.
This is the part that creates a practical planning problem: you can build towards a 2026 deadline, but you also need to assume the reporting mechanics could still shift.
3) Responsibility is pushed upstream: who submits the due diligence statement
A core structural change is that “operator” is now defined in a way that excludes downstream operators, reinforcing the idea that the entity placing the relevant product on the market (or exporting it) is the one that submits the due diligence statement.
Downstream actors still have obligations, but the centre of gravity moves upstream: more reliance on reference numbers and traceability through the chain, rather than repeated submissions.
4) A one time simplified declaration for micro or small primary operators (with an identifier)
The revision introduces a simplified regime for “micro or small primary operators”. Instead of full due diligence statement requirements, they submit a one time simplified declaration into the system and receive a declaration identifier for traceability.
There is also flexibility in what information is provided in that simplified route, including circumstances where address level information can substitute for plot geolocation, and where existing national or EU databases can reduce duplicative submissions.
5) Printed products removed from scope
Certain printed products have been removed from scope as part of the “targeted revision” package.
Why the delay matters for compliance teams
Delays like this do not reduce enforcement expectations. They change the sequencing.
Two things are now true at the same time:
- You have more runway to build the evidence trail your business will need by the end of 2026.
- The Commission is required to review and potentially reopen parts of the framework by April 2026, which means the “how” could still move while you are building.
That mix is why so many businesses and investors keep coming back to the same practical requirement: certainty. Even Reuters noted that some large food groups had warned against further delays because of the impact on forests and on investment planning.
What to do now: treat 2026 as evidence building time
If you are in scope, the safest approach is to assume the direction of travel is unchanged: you will still need defensible information about origin, traceability, and risk controls, and you will need it in a form you can evidence to regulators.
A pragmatic 2026 plan would include:
- Scope mapping: confirm which commodities and derived products you place on the EU market or export, and where the data sits across procurement, logistics and sales.
- Supplier data readiness: standardise what you ask suppliers for, and build escalation paths for gaps and refusals.
- Traceability and record keeping: align internal systems so reference numbers or identifiers can follow the product through your chain.
- Governance: assign clear accountability for who is the “operator” for each relevant flow, especially where distribution models and group structures blur responsibility.
- Training and internal reporting: make sure procurement, trade compliance, and sustainability teams understand what evidence they need to collect, and how to report issues early.
The bottom line
The December vote did happen, and the delay is now law. The new reality is a firm end of 2026 start date for most businesses, plus a mandated Commission simplification review by April 2026 that could still reshape parts of the process.
The best way to use the extra time is not to pause, but to get to a point where your organisation can answer one question confidently: if someone asks you to prove what you know about the origin and deforestation risk of an in-scope product, can you show your working?
