We’ve been quiet — EUDR Update: Six Months of Turbulence & What’s Next
We apologize for our extended silence over the past six months. As the saying goes, the only thing that is constant is change—and nowhere has that been truer than in the world of EU deforestation regulation. Since May 2025, the European Union Deforestation Regulation (EUDR) has undergone a dramatic transformation, with implementation timelines shifting, proposals being revised, and legislative positions evolving almost monthly. We felt it was crucial to wait until developments became clearer before sharing our insights, and now we have a much more complete picture to present
What is EUDR — quick refresher
The EUDR is the European Union’s regulation aimed at ensuring that certain imported/exported goods (such as cattle, cocoa, coffee, palm oil, rubber, soy, wood and related derived products) placed on the EU market are deforestation-free and do not contribute to forest degradation or illegal land conversion.
It replaces (for new production) the older EU Timber Regulation (EUTR) for timber and wood-products produced after EUDR’s entry into force.
Compliance under EUDR requires companies in the supply chain to conduct due diligence, document supplier information (including geolocation of production), and attest that goods meet the regulation’s “deforestation-free, legal” criteria.
The EUDR Landscape: From May to December 2025
The past seven months have been nothing short of a regulatory rollercoaster. What began as a seemingly firm December 2025 implementation date has morphed into something far more fluid, with delays, simplifications, and institutional realignments happening at a pace that would have been difficult to communicate clearly had we posted prematurely.
May 2025: Risk Benchmarking and Guidance Clarity
In May 2025, the European Commission took a step toward operationalizing EUDR by adopting an Implementing Regulation that classified countries according to their deforestation risk for the seven commodities covered by the regulation: cattle, cocoa, coffee, palm oil, rubber, soya, and wood. This development followed the publication of updated guidance and FAQs in April 2025, which introduced simplifications aimed at reducing administrative burdens on operators and making the regulation more workable in practice.
This period felt like a moment of stabilization—finally, businesses had clearer country classifications and updated guidance to work with. But it was the calm before the storm.
September 2025: The First Major Shock
On 23 September 2025, Environment Commissioner Jessika Roswall announced a proposal that would have fundamentally altered EUDR's trajectory. The Commission proposed postponing implementation by an entire year, citing a critical concern: the EUDR Information System would not be ready to handle the expected volume of transactions by December 2025. This was significant not just for what it proposed, but for what it signaled—that even the Commission itself recognized the regulation as currently designed might not be implementable on schedule.
For many businesses that had begun their EUDR compliance journey, this September announcement created a moment of uncertainty. Was December 2025 still happening? Would everything be delayed?
October 2025: A More Nuanced Approach
Rather than simply capitulating to a full one-year delay, the Commission revised its position. On 21 October 2025, it published a more sophisticated proposal that attempted to balance implementation concerns with environmental ambition. This revised approach was notably different from the September leak:
Under the October proposal:
Large and medium operators would begin compliance on 30 December 2025, with a six-month grace period for enforcement checks extending until 30 June 2026
Micro and small operators would receive until 30 December 2026 to comply - Read our opinion piece => The SME EUDR Paradox: Why Extended Deadlines May Not Help SMEs
Downstream operators and traders would be exempted from submitting separate due diligence statements
Simplified declarations would replace continuous due diligence statements for micro and small primary operators
This represented a strategic shift—rather than delay everything, the Commission proposed to differentiate implementation by company size and operational role, while introducing meaningful simplifications to reduce administrative burden.
November 2025: Institutional Alignment and the Path Forward
The legislative picture became clearer in mid-to-late November, when both the EU Council and the European Parliament moved decisively toward a unified position:
17-19 November 2025 (EU Council): The Council adopted an official negotiating position that went further than the Commission's October proposal. It called for a full one-year delay for large and medium operators to 30 December 2026, along with an even more extended timeline for small and micro primary operators to 30 June 2027 for non-timber products.
26 November 2025 (European Parliament): The Parliament voted decisively in favor of supporting a one-year delay, with 371 votes in favor, 240 against, and 30 abstentions. Importantly, the Parliament also mandated a simplification review to be completed by April 2026, ensuring that the additional time gained would be used to make the regulation more workable.
This convergence of positions was remarkable. With the Council and Parliament now aligned on the same core direction—a one-year delay coupled with meaningful simplifications—the three EU institutions entered trilogue negotiations to hammer out the final legal text.
The Current Moment (December 2025)
Here's the critical point: as of today, the original 30 December 2025 deadline remains legally binding. No amended regulation has yet been published in the Official Journal of the EU. However, with all three institutions now aligned on supporting a one-year delay and pursuing simplification measures, a final agreement is expected to be reached before the end of this year, with formal adoption anticipated around 15-18 December.
Once the final text is adopted and officially published, the delays will take effect, and businesses will have significantly more time to prepare for full EUDR compliance.
Why We Went Silent: Navigating Constant Change
This extended period of silence was intentional. Posting regularly about a regulation that was fundamentally in flux—with the Commission changing its position, the Council and Parliament diverging, and implementation timelines shifting—would have been irresponsible. We wanted to wait until we had enough clarity to offer genuinely useful guidance rather than a series of "EUDR news flash" posts that might become outdated within weeks.
The reality is that regulatory environments don't always move in neat, predictable ways. Sometimes the most helpful thing a communicator can do is wait for clarity before speaking. We believe we've now reached that point.
What This Means for Your Business
If your company is subject to EUDR, here are the key takeaways:
For large and medium operators: You have until 30 December 2026 to achieve full compliance (extended from the original December 2025 deadline), with a potential six-month grace period for enforcement checks.
For micro and small operators: The compliance timeline extends to 30 December 2026 or 30 June 2027, depending on whether your products are timber or non-timber.
For traders and downstream operators: You may face simplified requirements compared to earlier versions of the regulation.
Simplifications are coming: The parliament's mandate for a simplification review by April 2026 suggests that the additional time will be used to make the regulation genuinely more workable, not just to kick the can down the road.
Looking Ahead
The next critical date to watch is around 15-18 December 2025, when the final text is expected to be formally adopted. Once published in the Official Journal, the new timeline will become the legal standard.
Beyond that, keep an eye on April 2026, when parliament-mandated simplifications are scheduled to be reviewed and implemented. This suggests that the regulatory landscape will continue to evolve, but ideally in ways that make compliance more feasible rather than less.
The Constancy of Change
Six months of silence may have felt long, but it reflected a fundamental truth about modern regulation: the only thing that is constant is change. The EUDR journey exemplifies this perfectly. What appeared to be a fixed deadline in May 2025 has transformed into a more complex, differentiated, and hopefully more workable framework by December 2025.
We're committed to keeping you informed as the EUDR landscape continues to evolve. Thank you for your patience during this period of regulatory flux—and for understanding why we chose to wait until we had something truly useful to share.
EUDR Services
We can help with all the above and more. Should you have any questions, concerns or would like to discuss EUDR in general, do not hesitate to get in touch with us. Email us at: questions@eudrservices.com
Useful links and resources:
https://www.consilium.europa.eu/en/press/press-releases/2025/12/04/eu-deforestation-law-council-and-parliament-reach-a-deal-on-targeted-revision/
https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
https://www.eeas.europa.eu/guidance-doc-eudr_en
https://green-forum.ec.europa.eu/deforestation-regulation-implementation/information-system-deforestation-regulation_en
https://op.europa.eu/en/publication-detail/-/publication/1a2e1648-f007-11ef-981b-01aa75ed71a1/language-en
https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/ENVI/DV/2023/11-20/FAQ-Deforestation_Regulation_EN.pdf