The EU Deforestation Regulation in 2026
2025 has been another significant year for companies preparing for compliance with the EU Deforestation Regulation (EUDR). Following the initial 12‑month delay announced at the end of 2024, which gave many organizations additional time to adjust, 2025 introduced further developments. These included proposals for simplification, debates around key deliverables, and eventually an additional one‑year postponement.
This article summarizes where the regulation stands today and what the updated timelines and scope adjustments mean for businesses and their supply chains.
TL;DR
Application dates have been postponed by 12 months.
A new company category—micro and small primary operators—has been introduced with reduced obligations.
Due diligence requirements have been simplified for downstream operators.
Printed products are no longer in scope.
Further simplification proposals are expected by April 2026.
Join our webinar on 15 January 2026 for a live discussion with our partner Produktkanzlei: Deep Dive into the EU Deforestation Regulation (EUDR): Roles, Responsibilities, and Practical Scenarios.
Updated Date of Application
The EUDR application dates have been postponed by one year:
30 December 2026 for medium and large organizations.
30 June 2027 for micro and small organizations.
Key implications of the new dates
The EU Timber Regulation (EUTR) remains in force for an additional year.
EUDR commodities or products placed on the EU market before the new dates are exempt, even if they are later used to manufacture new EUDR‑covered products. Operators may continue using the conventional reference number for these items.
EUDR commodities or products purchased from a micro or small organization before 30 June 2027 are exempt, even when acquired by a medium or large organization.
Simplification Measures
Introduction of a New Company Category
A new category—micro and small primary operators—has been added. These are operators in low‑risk countries who grow an EUDR commodity and place it on the market for the first time. Their responsibilities regarding due diligence statements are reduced, as outlined below.
Changes to the Due Diligence Statement (DDS)
Only the upstream operator placing a product on the EU market for the first time must submit a DDS and keep the reference number.
The first downstream operator does not submit a DDS but must retain the DDS reference number provided by the upstream operator.
All further downstream operators are not required to submit a DDS or retain any reference number.
Micro and small primary operators only need to submit a one‑time simplified declaration, including an estimated quantity.
These operators may provide postal addresses instead of geolocation coordinates.
Scope Exclusion
Printed products (ex 49)—including printed books, newspapers, pictures, and other printed materials—are no longer covered under the EUDR.
Additional Simplifications Expected
The European Commission is expected to propose further simplifications by 30 April 2026 at the latest.
What Companies Should Do Now
Assess how the revised timelines and definitions affect your products and supply chains.
Confirm whether any of your products are now exempt from the EUDR.
Identify which of your products remain under the scope of the EU Timber Regulation.
Review your EU‑based suppliers and determine whether they qualify as medium/large or micro/small organizations.
Ensure continued compliance with the EUTR during the transitional period for timber and timber‑based products.
Use the extended preparation time to inform and train suppliers, reinforce traceability, and implement effective risk management procedures.
Evaluate whether your products originate from High Risk or Standard Risk countries and conduct early risk assessments and mitigation.
Review and adjust your EUDR due diligence framework where needed.
Contact us if you require support and join our webinar on 15 January 2026 for a live discussion with our partner Produktkanzlei: Deep Dive into the EU Deforestation Regulation (EUDR): Roles, Responsibilities, and Practical Scenarios.
FAQs
Q1. What are the new EUDR application dates? Medium and large organizations must comply from 30 December 2026. Micro and small organizations must comply from 30 June 2027.
Q2. Does the EU Timber Regulation remain in effect? Yes. Because of the postponed EUDR application dates, the EU Timber Regulation (EUTR) will continue to apply for one additional year.
Q3. Are products placed on the EU market before the new application dates exempt?
Yes. EUDR commodities or products placed on the EU market before the new dates are exempt, even if used afterward to produce an EUDR‑covered product. Operators may use the conventional reference number for these products.
Q4. Are products from micro or small organizations treated differently?
Yes. Commodities or products purchased from a micro or small organization before 30 June 2027 are exempt, even if purchased by a medium or large organization.
Q5. Who must submit a Due Diligence Statement (DDS)?
Only the upstream operator placing the product on the EU market for the first time must submit a DDS and keep the reference number.
Q6. Do downstream operators need to submit a DDS?
The first downstream operator does not need to submit a DDS but must keep the reference number. All further downstream operators do not need to submit a DDS or keep the reference number.
Q7. What obligations apply to micro and small primary operators?
They must submit a one‑time simplified declaration with an estimated quantity and may use postal addresses instead of geolocation coordinates.
Q8. Which products are no longer in scope of the EUDR?
Printed products (ex 49), such as printed books, newspapers, pictures, and other printed materials, are excluded.
Q9. Will there be more simplifications to the EUDR?
Yes. The European Commission is expected to propose further simplifications by 30 April 2026 at the latest.
Q10. What should companies focus on during the transition period?
Companies should assess product scope changes, ensure compliance with the EUTR, train suppliers, reinforce traceability and risk procedures, complete risk assessments for High and Standard Risk countries, and review their EUDR due diligence framework.
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