EU: One-year postponement of EUDR

 

Under the position adopted by the European Parliament on 26 November, large and medium-sized companies will only need to comply with EUDR obligations from 30 December 2026, while micro and small enterprises will become subject to the new rules from 30 June 2027. The additional year is intended not only to facilitate smoother internal adjustments, but also—above all—to allow further development and optimisation of the EU’s IT system for submitting due diligence statements (DDS). This revised timeline represents a major departure from the European Commission’s October proposal, which had maintained the original dates (30 December 2025 for large and medium-sized companies, with a six-month transitional period, and 30 December 2026 for micro and small enterprises).

Updated application timeline following Parliament’s amendments:

Entity type	Date of application
Medium-sized and large enterprises	30 December 2026 (no transitional period)
Micro and small enterprises	30 June 2027

Key simplifications – what has changed?

The European Parliament has clearly opted for deregulation and reduced administrative burden. The most important changes include:

1. Fewer obligations within the supply chain

Only the operator first placing a product on the EU market will be required to submit a DDS. Subsequent supply-chain actors, especially traders, will no longer need to submit their own statements. Traceability requirements will focus primarily on the first downstream operator rather than the entire chain.

2. Removal of the requirement to pass on DDS numbers

DDS reference numbers and simplified declaration identifiers must be transferred only by operators placing products on the market for the first time.

3. One-off simplified declaration

Micro and small primary operators will no longer need to submit a DDS for each transaction. Instead, they will file a one-off simplified declaration, valid as long as no material changes occur in product or producer data. Updates will be required only if significant changes arise. If using a national database, data may be transmitted directly to the EU system, with only the declaration identifier needed.

4. New geolocation rules

Micro and small primary operators may provide only the postal address of plots or facilities from which relevant commodities originate, instead of detailed geocoordinates as required by the current EUDR.

5. Books and newspapers removed from EUDR scope

Annex I has been amended to exclude code ex 49—books, newspapers, images, and other printed products, as well as manuscripts, typescripts and plans on paper.

6. Review of EUDR impacts by 30 April 2026

Parliament has mandated a detailed review of the administrative burden and simplification needs by 30 April 2026. This is separate from the broader assessment of EUDR functioning provisionally scheduled by the Council for 30 June 2030.

It is worth noting that Members of Parliament rejected several amendments that would have significantly changed the Regulation’s scope—most notably, the proposal to create a new category of “no-risk” countries (exempt from due diligence) and the proposal to exclude leather (ex 4101, ex 4104, ex 4107) from the EUDR’s material scope.

EUDR – scope, purpose, and business obligations (recap)

The EUDR entered into force on 29 June 2023 and applies to the import or export of products containing or derived from the following commodities: cattle, cocoa, coffee, oil palm, soya, rubber and wood, produced after the Regulation’s entry into force. It establishes comprehensive due diligence obligations—information gathering, risk assessment and mitigation—and requires full traceability of product origin. Its core aim is to reduce deforestation and forest degradation, contributing to climate-change mitigation and biodiversity protection.

Originally, the Regulation was to apply across all supply-chain actors, requiring significant system upgrades and internal process adjustments—changes that many businesses indicated they were unprepared for. In response, the Commission proposed several amendments to ensure smoother implementation and allow operators and traders to adapt, particularly through the roll-out and improvement of DDS submission IT systems.