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EUDR 2025 Delay: What You Need to Know About the Latest Updates
A delay to EUDR 2025 has been proposed, bringing uncertainty to many businesses. Here's what you need to know.
Published October 31, 2025
Asharita D'Silva
Expert@Era of We
The European Union Deforestation Regulation (EUDR) represents one of the most ambitious sustainability initiatives ever undertaken by the EU, aiming to curb deforestation linked to global supply chains. However, as the December 2025 enforcement date approaches, the European Commission has proposed a partial delay and adjustment to its rollout.
This move reflects the operational, technical and administrative challenges that both regulators and businesses face in implementing such a data-intensive framework. For European operators and global exporters alike, the postponement provides valuable breathing space to align due diligence systems, data management, and supplier engagement processes.
Yet the direction of travel remains unchanged: the EU expects companies to ensure full traceability and “deforestation-free” sourcing. Understanding what the delay covers and what it does not is now critical for procurement, compliance, and sustainability leaders across industries preparing for the next compliance phase under EUDR.
Why Was a Delay Proposed?
There are multiple drivers behind the proposed postponement of full enforcement under the EUDR. The key elements are:
- Operational readiness concerns: The European Commission has pointed to capacity constraints in its planned IT infrastructure, the “EUDR Information System”, intended to receive and process large volumes of due diligence statements from companies.
- Volume of compliance submissions: Industry and the EU suggested that the number of required submissions may be far higher than originally estimated, potentially hundreds of millions to a billion annually. This places a strain on both companies and regulators.
- Stakeholder push-back: Producers and traders exporting commodities such as palm oil, soy, beef, and cocoa have raised concerns about readiness, costs of compliance, and competitive distortions. For example, Malaysia’s palm oil body welcomed extra time to prepare.
- Competitive/market concerns: Some large agribusinesses have flagged that uncertainty about the regulation timeline hinders investment and supply-chain planning.
- Regulatory flexibility and simplification demands: Some EU member states and industry from within the EU have advocated for lighter burdens for smaller operators, downstream traders and micro-suppliers. The Commission’s recent proposals reflect that.
In short, the delay proposal is not just about extra time but about redesigning the “how” of EUDR entry, i.e., the administrative burden, data systems, and roles/responsibilities of companies in the supply chain.
The Challenges of EUDR and Data Management
For companies operating within or exporting to the EU market, the EUDR presents several interconnected challenges centered around data, supply-chain visibility and risk-management, including:
Traceability and geolocation requirements
Operators will need to provide geolocation (coordinates or polygons) of production units, map supply chains back to the origin of commodities, and demonstrate conformity with local law and “deforestation-free” status (i.e., no forest conversion after 31 December 2020).
Due diligence statements (DDS) and reporting obligations
A core part of the EUDR is the obligation on operators/traders to submit a DDS to a central information system and document risk assessments, mitigation actions and verification of supplier practices. The volume and complexity of these obligations are cited as major bottlenecks.
Data system reliability and administrative load
The need for a robust IT platform that can handle massive submissions, cross-check data from multiple countries, risk-classify sourcing regions, and enable competent authorities to enforce compliance is cited as a key constraint. The Commission’s proposal references “reducing load on the information system”.
Downstream vs upstream responsibility
The regulation designates upstream operators (those placing the first product on the EU market) as the primary complying party. Downstream traders, retailers and processors must still verify chain integrity but face lower direct obligations. However, this demarcation raises supply-chain coordination, contract, audit, and data sharing challenges.
SMEs, micro-operators and risk classification
Smaller producers and operators (micro or small enterprises) often lack resources, data management systems, and supplier mapping capability. The Commission’s recent proposal aims to ease obligations for them (including one-time declarations), but from a business perspective, this still raises questions about readiness and integration with larger networks.
Global sourcing and third-country compliance
Many affected commodities are produced outside the EU. Ensuring local legality (of land-use, forest conversion, labour, export arrangements), collecting required data, and dealing with suppliers across jurisdictions poses significant complexity and risk.
Companies must assess not only their direct operations, but the broader upstream (and partially downstream) supply-chain ecosystem, map risk-points, invest in data/IT systems and coordinate with suppliers, often in multiple geographies.
The Current Status of EUDR
Here is a summary of where things stand (as of October 2025) with key dates, obligations and proposed changes:
- The Regulation, formally Regulation (EU) 2023/1115, entered into force in June 2023.
- The initial application date was pushed back from 30 December 2024 to 30 December 2025 for large/medium operators.
- On 21 October 2025 the European Commission confirmed that large and medium enterprises must comply from 30 December 2025 (legal obligations commence).
- For micro and small enterprises (“micro/small primary operators”) the Commission has proposed postponing their full obligations until 30 December 2026 (instead of June 2026) under its amendment proposal.
The Commission has also proposed a six-month grace period for checks/enforcement by competent authorities for larger operators (i.e., enforcement starts ~30 June 2026 for large operators), while micro/small operators may face enforcement later.
The proposed amendments include simplification measures: exempting downstream operators from submitting DDS if upstream has done so; micro/small operators in low-risk countries may only need a one-time simplified declaration; reduced burden on small and micro primary operators.
Although the delay of full enforcement for large operators to 2026 was discussed, the Commission rejected a blanket one-year delay for all.
From a legal standpoint, until the amendment is formally adopted by the European Parliament and Council, the legally binding application dates remain the originally agreed ones.
Business implications: Companies cannot rely on a uniform delay; large operators must act as if the 30 December 2025 deadline is firm while considering a phased approach, transitional enforcement, and special provisions for smaller actors. The exemptions for downstream traders in Due Diligence Statements will reduce some degree of complexity, but they will still have massive amounts of data to work with and store, which would be Reference Numbers and Verification Numbers.
What Can Companies Do to Prepare for EUDR in 2025
The following steps outline practical priorities for businesses preparing for the next phase of EUDR implementation:
1. Strengthen due diligence systems and documentation
Develop or upgrade digital tools to manage Due Diligence Statements (DDS), record supplier verification data, and integrate with the EU’s upcoming EUDR Information System.
2. Establish supplier engagement and data-sharing protocols
Work with upstream suppliers, especially outside the EU, to gather necessary land use, legality, and traceability information. Build long-term capacity and training in local sourcing regions.
3. Plan for documentation and audit readiness
Maintain traceable records to demonstrate conformity during potential audits or enforcement reviews starting mid-2026.
4. Monitor regulatory updates and amendments
Track developments in the European Parliament and Council as the EUDR amendment proposal progresses, to adapt plans accordingly.
The proposed EUDR delay does not signal a retreat from the EU’s sustainability agenda, but rather it marks a recalibration to ensure credible, enforceable compliance. Large operators still face a binding December 2025 deadline, while smaller enterprises may benefit from phased or simplified obligations.
For businesses, this transitional period is an opportunity to strengthen internal governance, enhance supplier transparency, and invest in data systems capable of managing due diligence at scale. With the Commission emphasising digital readiness and proportionality, proactive engagement will be key, and companies that prepare now will reduce future disruption and gain a competitive advantage when enforcement intensifies in 2026.
Sustainability Practices
About the author
Asharita D'Silva
Join me in discovering the wonderful world of coffee! As a writer, coffee is my fuel and newfound passion. I love writing about new coffees, sustainability, and coffee culture around the world. I'm always discovering new things about coffee and the industry, which I share with the great community here at Era Of We.
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