Advisory

EUDR Update — What it is, impact on companies, and the proposed delay

jochen van kerckhoven
By:
Jochen Vankerckhoven
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Contents

What is the EUDR?

The EU Deforestation Regulation (EUDR) requires that certain commodities placed on or exported from the EU market are proven to be deforestation-free, legally produced, and traceable to plot level. It covers cattle, cocoa, coffee, palm oil, rubber, soy, and wood, plus a defined list of derived products. Companies must collect detailed supply chain data, conduct risk assessments to ensure negligible risk, and submit Due Diligence Statements via the EU’s new Information System. Penalties can reach at least 4% of annual EU turnover and may include confiscation of goods and temporary bans from procurement.

Who is affected?

The regulation impacts food and beverage producers, retailers, luxury and fashion brands, wood and paper industries, rubber and tyre makers, and companies using palm-based chemicals. SMEs face lighter obligations but are still within scope. Key challenges include obtaining geolocation data from millions of smallholders, ensuring IT readiness for the EU Information System, and updating supplier contracts to align with EUDR requirements.

Proposed delay

The regulation entered into force in June 2023, with application originally planned for December 2024. This was already delayed by one year to December 2025 (and June 2026 for small or micro companies). The European Commission has now proposed a further one-year postponement, citing readiness concerns with the Information System. If approved by Parliament and Member States, the new deadlines would move to December 2026 for most companies and June 2027 for SMEs.

What companies should do now

The delay does not change the obligations, only the timing. Companies should use the extra time to map their exposure, gather geolocation data, prepare due diligence workflows, strengthen supplier agreements, and rehearse compliance processes. Those who start early will be better placed to avoid costly disruption and reputational risk once enforcement begins.