EU Deforestation Regulation: Enforcement delayed, but expectations remain high

The European Parliament has approved amendments to the EU Deforestation Regulation (EUDR) that delay enforcement and introduce targeted simplifications, particularly for smaller companies. The intention is to give operators more time to build the data and processes needed for deforestation free supply chains, without weakening the core due diligence obligations.

Updated timelines for compliance

Under the amended timeline, companies now have additional time to comply with EUDR requirements.

• Large and medium sized operators and traders must comply by the end of 2026.
• Micro and small enterprises have an extended deadline until the end of 2027.

These changes do not remove any obligations; they only postpone when enforcement will begin.

Targeted changes to reduce administrative burden

The amendments introduce several clarifications and reliefs aimed at making implementation more practical, especially for smaller businesses and specific sectors.

• Micro and small operators may submit simplified due diligence statements and can use postal addresses instead of exact geolocation coordinates for plots of land, reducing complexity in data collection.
• Only the first operator in the supply chain placing products on or exporting them from the EU market will need to submit a full due diligence statement in TRACES; downstream actors can rely on that statement and supporting documentation instead of duplicating submissions.
• Printed books, newspapers and similar printed media are excluded from the scope of EUDR, while packaging materials remain covered and must still meet all regulatory requirements.

These changes are intended to focus regulatory efforts where the deforestation risk and leverage are highest, while still preserving traceability and accountability.

No relaxation of due diligence obligations

Proposals to classify certain jurisdictions as “zero risk countries” with lighter obligations were not accepted, meaning that full due diligence continues to apply to all covered commodities and products, regardless of origin. Companies must still be able to demonstrate that their supply chains are deforestation free and compliant with local laws in producer countries.

The European Commission is expected to review the functioning of EUDR by April 2026 and may recommend further adjustments, but the strategic direction towards robust forest risk due diligence is unchanged.

Pre-Assessment: The Critical First Step

While the delay offers more time, the work must start now—specifically with the pre-assessment phase. Before you can collect geolocation data, you first need to analyze your entire product portfolio to identify exactly which products contain relevant commodities like rubber, soya, or palm oil.

This step is often underestimated but is essential: many manufacturers have "hidden" commodities in their Bill of Materials (BOM), such as rubber gaskets in larger assemblies or soya derivatives in chemical formulations. Without this systematic pre-assessment, you cannot identify which suppliers need to be engaged, making compliance impossible.

Request a demo today to learn how CDX can help you with this stage.