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12/04/2025
The EU Regulation on deforestation and forest degradation, commonly referred to as the EU Deforestation Regulation (EUDR), was initially scheduled to apply from 30 December 2024 for large operators and traders, and from 25 June 2025 for micro and small enterprises.
In October 2024, the European Commission proposed a one-year postponement of these deadlines, to 30 December 2025 and 30 June 2026 respectively, without altering the substance of the requirements. This proposal was subsequently approved by both the European Parliament and the Council.
The timeline has since shifted again. In autumn 2025, the Commission put forward a further one-year delay, with a new proposed application date of 30 December 2026 for medium-sized and large operators and traders, and 30 June 2027 for micro and small enterprises established before 2021.
In parallel, the European Parliament voted in November 2025 in favour of a second postponement combined with targeted simplifications. However, the final legislative text resulting from negotiations between the Parliament and the Council has yet to be adopted and will need to confirm both the exact dates and the modalities for any phased application.
The co-legislators have also called for a review of the framework by 30 April 2026, to assess the administrative burden associated with due diligence obligations and, if necessary, to propose adjustments even before full application of the Regulation.
This adjustment to the implementation schedule, still under discussion within the EU legislative process involving the Commission, the Parliament and the Council, is accompanied by proposals to amend certain due diligence requirements, as outlined below.
Several factors explain the renewed delay. On the one hand, the rollout of the EU information system intended to receive due diligence statements still requires technical refinements and raises concerns about potential system overload. On the other hand, many companies, particularly SMEs, have reported difficulties in mobilising the human, financial and operational resources needed within the original timelines.
By autumn 2025, the co-legislators considered the initial schedule no longer workable in practice. In their view, the deployment of the information system, the readiness of economic operators and the necessary upskilling of SMEs all required additional time. This shared assessment led them to support a broader adjustment of the deadlines, through a postponement and potentially a phased implementation.
They also converged on a key principle: to reduce administrative burden, responsibility for due diligence statements should be refocused on first placers on the EU market, while downstream operators would mainly be required to retain documentary evidence based on a reference number. This approach aims to ensure traceability while avoiding duplication of obligations, but it still needs to be confirmed in the final legal text.
These positions must still be consolidated and formally adopted. In the absence of final agreement on this new postponement, the deadlines set out in the previous version of the Regulation would apply.
By way of background, the Regulation was adopted in April 2023 by a large majority in the European Parliament and published in the Official Journal of the European Union in June 2023, establishing a cornerstone framework to address imported deforestation.
The Regulation pursues three overarching objectives:
This synthesis reflects the spirit of the Regulation, even though these objectives are not formally listed as such in the legal text.
More specifically, the EUDR aims to:
The Regulation applies to seven commodities and their derived products:
The 2025 revision does not alter this scope.
Companies will need to demonstrate that the production of these commodities complies with the laws of the country of origin and has not resulted in deforestation or forest degradation since 31 December 2020, the reference “cut-off date” set by the Regulation.
This date aligns with existing international commitments, including:
As a regulation, the EUDR will apply uniformly across all EU Member States.
Periodic reviews are foreseen, in principle one, two and five years after application, to assess whether the scope should be extended to other wooded land and biodiversity-rich ecosystems such as peatlands, and potentially to additional sectors including finance, maize and certain biofuels. These extensions remain under consideration and are not yet subject to a legally binding timetable.
Products placed on the market must be deforestation-free, with deforestation defined as the conversion of forest land to agricultural use after 31 December 2020.
For wood products, this means they must originate from forests harvested without degradation after that same date, in line with the Regulation’s requirements.
Products must also be produced in compliance with the legislation of the country of origin, covering land-use rights, environmental protection, forest governance, labour law, human rights, free, prior and informed consent (FPIC) of Indigenous Peoples, as well as relevant rules on taxation, trade, customs and anti-corruption.
Finally, the products concerned must be covered by a due diligence statement based on three steps:
In autumn 2025, proposals were put forward to simplify these obligations, notably by further concentrating responsibility on first placers on the market, while downstream operators would primarily retain the reference number associated with the initial due diligence statement. A lighter procedure is also being considered for micro and small primary operators.
These changes are still under discussion and have not yet all been definitively adopted.
Since 2023, a dedicated platform has brought together representatives from Member States and relevant sectors. Its work is supported by two sub-groups:
Several support tools are planned, including:
A further review of the framework is scheduled by 30 April 2026 to assess the administrative burden, particularly for SMEs.
A European Forest Observatory is currently being established. It will include:
The first maps have been available since December 2023.
The publication of the country and regional risk benchmarking is still awaited. At this stage, no country has been formally classified. In France, the competent authority was designated at the end of 2023.
Initial inspections were due to begin in 2025, but the postponement supported by the co-legislators is expected to delay them by one year. Companies are nevertheless encouraged to prepare now.
EVEA’s teams can support you in analysing your supply chains and identifying risks related to deforestation or non-compliance with environmental and social legislation.
Topic monitored by Mathilde Verrier, LCA and eco-design consultant.
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