Deforestation-free supply chains from 2026 at the earliest – a longer road with fewer obstacles

The European Union has postponed the EU Regulation on deforestation-free products (EUDR) once again. In addition to extending the timeline, the European Parliament has also eased certain content requirements. The amendments, published in the Official Journal, officially entered into force on 26 December 2025. Having previously outlined the regulation’s main provisions and reported on the first postponement of its application date, we now provide you with an overview of the latest developments.

New deadlines: When will the regulation come into force?

Large and medium-sized operators must apply the EUDR from 30 December 2026. Micro and small enterprises have until 30 June 2027 to comply. Legal departments of affected corporations can breathe a sigh of relief: all companies now have an additional year to implement the new EU regulations.

The revised regulation also substantially simplifies several aspects:

Relief for downstream operators

Only operators who place a relevant product on the EU market for the first time must submit a due diligence statement. Downstream operators and traders are no longer required to submit such a statement, avoiding redundancy. Additionally, the EU has removed the obligation to pass on reference numbers of due diligence statements along the supply chain. Only the first downstream operator must collect and store the reference number of the original statement.

A practical example illustrates this simplification: an importer of cocoa beans who places them on the EU market must submit a due diligence statement. Downstream manufacturers of chocolate products need only retain the reference number of the importer’s statement, rather than entering a new statement in the TRACES-NT system. Other downstream operators or traders in the supply chain need not record or store the reference numbers at all. This significantly reduces the administrative burden throughout the value chain.

Simplifications for micro and small primary operators from countries with low deforestation risk

Micro and small primary operators from countries without deforestation problems relevant to the EUDR benefit from the amended Article 4a EUDR. They need only submit a one-time simplified declaration instead of a due diligence statement. Furthermore, it is sufficient for them to (i) provide their business address instead of geodata of the business premises, (ii) provide estimated quantities of relevant products, and (iii) update information only in the event of major changes.

Further simplifications in prospect

Additional adjustments may follow in the coming years. The European Commission will report to the European Parliament and the Council by 30 April 2026 on the administrative burden of the EUDR and examine further possible simplifications. The EUDR also provides for the Commission to review the regulation regularly thereafter.

No respite, but preparation time

Affected companies should actively use the time they have gained. The core of the regulation remains unchanged: the definition of "deforestation-free" stays in place, and companies must still prove that no deforestation has taken place and provide precise geographical coordinates – medium-sized and large enterprises in full detail.

Specific recommendations for action

The new implementation deadlines give affected companies more time to prepare. During this period, companies should consider the following steps:

• Review and adjust supply chains to ensure traceability
• Implement appropriate data collection systems for geolocation
• Prepare to use the EU’s TRACES-NT system
• Train relevant staff in compliance, purchasing and logistics departments
• Assess whether the company is classified as a first distributor or downstream operator
• Analyse the countries of origin of the commodities
• Establish a risk management and documentation system
• Communicate with suppliers about the new documentation requirements

Stay informed

As the Commission will be considering further simplifications until April 2026, additional relief measures may follow. We continue to monitor developments closely and will inform you of any relevant changes promptly.