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Navigating the EUDR Delay: What It Means for Your Business


On Wednesday, October 2nd, the EU surprised everyone with a press release, announcing a proposed 12-month delay for the EU Deforestation Regulation (EUDR). This comes after months of pressure from both EU and non-EU countries, trade organizations and companies. Just last week, the EU informed the WTO that it was not considering a delay, yet here we are.

The proposed delay, pending approval from the European Parliament and Council, would shift the applicability dates by one year to December 30, 2025, for large companies and June 30, 2026, for micro- and SME companies.

On the same day, the EU delivered on several outstanding elements:

Updated EUDR website

The EU’s dedicated EUDR website has been updated and restyled. It now includes key elements and definitions of the regulation, links to new and updated documents, and a new ‘EUDR Myth-buster’ page.

Updated EUDR FAQ

After 10 months, the EUDR FAQ has been updated. New and updated information is marked ‘NEW’ for easy reference. Some new elements include:

The FAQ also clarifies domestic business relationships, processes during the transitional period, and states that bamboo is not within the EUDR’s scope.

EUDR Guidance

The European Commission has also released a guidance document on the EUDR. The following items are covered:

TARIC data document

Finally, the EU has published a document that clarifies which codes to use when you are importing products in the scope of EUDR, but the products are eligible for an exemption. This is how customs authorities will know why for the import of a relevant product no Due Diligence Statement reference number is mentioned.

The day after the announcement of the proposed delay, QIMA hosted a Fireside chat with Pallavi Sharma, Food, Agriculture and Biodiversity Lead at Business and Human Rights Compliance (BHRC). We discussed the proposed change and how it would affect companies. With the EUDR being a strict liability law, and the amount of work needed to get supply chains ready and commodities and products in compliance, we concluded that companies cannot stop what they’re doing. On the contrary, they should press on with implementation to ensure EUDR compliance, whenever the law becomes applicable to them.

More updates

While the world is holding its breath on the proposed delay, the EU presses on and has delivered the following on October 8:

Legislative text

The actual proposal for a regulation amending the EUDR is now available. It focuses on amending articles 29 (paragraph 2), 37 and 38 (paragraphs 2 and 3) which cover relevant timelines. It remains to be seen if the European Parliament and the Council will vote on this as is and on time, or whether they will try to re-open the entire regulation.

Information System Virtual Training Sessions

Spoiler alert: The training sessions are already fully booked immediately after they were released. The EU has posted registration forms for a number of training sessions on the EUDR Information System (TRACES) in October. As many others, we have written to ask for more sessions to be organized, allowing everyone interested to attend. We hope the sessions will also be recorded and made available to a wider audience.

Information System User Guide

A User Guide is now available on Circabc, outlining how to get set-up, create and manage due diligence statements in the future TRACES system.

What all this means for businesses in scope of the EUDR

As the proposed delay by the European Commission is yet to be approved, businesses should not assume that this delay is confirmed. If approved, companies will have more time to make sure their products are EUDR compliant.

Companies cannot afford to relax and sit back but should make use of the extra time to engage with their supply chain, map the supply chains of the relevant products all the way to the farms and forest, collect data and information and perform risk assessments.

In the meantime, check out our EUDR Checklist and EUDR Fireside Chat to learn more.


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