Another planned delay to the EUDR: what does the European Commission's decision mean for businesses and forest protection?

Day 23 September 2025 The European Commission has presented a proposal the second postponement of the entry into force of the EU Deforestation Products Regulation (EUDR)Under the new proposal, full enforcement of the regulations is expected to begin December 31, 2026, which is as much as 12 months later than planned after the first correction.

This decision immediately sparked a wave of comments from both environmental organizations and businesses, which had been investing significant resources for many months to adapt to the new requirements. Members of AFi Coalition, bringing together key international NGOs and think-tanks dealing with sustainable trade, supply chain transparency and the fight against deforestation.

Why is EUDR so important?

The EUDR (EU Regulation 2023/1115) was adopted in June 2023 as a groundbreaking piece of legislation to ensure that products placed on the European Union market do not come from areas associated with deforestation or forest degradation after December 31, 2020

It covers a number of key commodities such as:

• wood and wood products,

• cocoa, coffee, soy, palm oil, rubber,

• derived products (e.g. paper, plywood, furniture, packaging),

• as well as selected meat and feed products.

For importers, producers and exporters, this means the obligation to:

1. Conducting due diligence for each batch of goods.

2. Presentation of the geolocation of raw material production plots.

3. Submitting a digital DDS (Due Diligence Statement) in the EU TRACES system.

The aim of the regulation was clear: to limit the EU's contribution to global deforestation, which contributes to climate change and biodiversity loss.

Controversial Commission proposal – voices of opposition

The EC's announced proposal has sparked considerable controversy. Social organizations warn that another postponement undermines the credibility of the EU's climate and environmental commitments, while simultaneously placing businesses that have already adapted their processes to the new reality in a difficult position.

Global Canopy

Według Global Canopy, the shift in regulation is a blow to those who have already invested in compliance:

“Companies and administrations that have put effort into mapping supply chains and preparing for the EUDR should not have the ground removed from under their feet.”

Mighty Earth

Mighty Earth called the decision "completely unacceptable." The organization noted that the delay "massively discriminates against companies and countries that were ready for the regulation to begin in December of this year." The NGO also added that the EC's decision coincided with new trade agreements with the US and Indonesia—which may suggest political pressure from partners concerned about the impact of the EUDR.

Preferred by Nature

Preferred by Nature, on the other hand, has taken a more pragmatic stance. The organization advises companies to, despite the postponement, "they didn't slow down"In her opinion, preparations for the EUDR should be treated as a long-term investment in competitiveness and transparency.

Proforest

Proforest draws attention to two dimensions of the problem:

1. Uncertainty for business – subsequent changes in deadlines make strategic planning and building investor confidence more difficult.

2. Failure to take into account the role of small producers – the regulation still does not solve the problem of supporting small farmers who are an integral part of supply chains in sectors such as cocoa and coffee.

Rainforest Alliance

Rainforest Alliance called the EC's decision "a blatant violation of all EU commitments to halting biodiversity loss and combating climate change." The organization notes that the European Union has made international commitments to halting deforestation by 2030.

World Resources Institute (WRI)

WRI emphasizes that "the EU must reject attempts to weaken key EUDR requirements" and, at the same time, "urgently step up efforts to issue clear guidance for businesses." The lack of detailed interpretative guidance is one of the biggest challenges facing businesses today.

WWF

WWF warns that the delay could "lead to further dilution of the law, with dire consequences for the world's forests." According to WWF, every year of delay means millions of additional hectares of tropical forests are at risk of degradation.

Business implications: risks and opportunities

1. Regulatory uncertainty

Companies today operate under conditions of changing implementation dates. This complicates planning and, for some, translates into additional costs related to downtime in preparations.

2. Growing social pressure

Despite the delay, social organizations, investors and consumers expect that business will not withdraw from work on the transparency of supply chainsCompanies that ignore these expectations risk reputational damage.

3. Opportunity for leaders

Companies that implement due diligence systems today will gain a competitive advantage. Customers and partners will prefer to work with providers that can guarantee EUDR compliance, even if the regulations enter into force later.

4. Possible weakening of regulations

Some experts fear that further postponements are a prelude to further trials. weakening the regulation itself – e.g. by introducing exceptions or lowering the evidentiary requirements.

What's Next? 2026 Outlook

While the EUDR's full obligations may not formally come into force until the end of 2026, this does not change the fundamental thrust of EU policy. Transparent and deforestation-free supply chains remain a key element. European Green Deal and the EU trade agenda.

Companies should use the extra time to:

• construction of internal procedures Due Diligence Statement (DDS),

• implementing digital tools enabling the collection of geolocation data,

• training for purchasing and compliance teams,

• development of cooperation with suppliers in third countries.

Wnioski

The delay in EUDR is on the one hand relief for companies that are late with preparations, and on the other – disappointment for those who were ready on timeIn practice, this means that businesses cannot afford to pause operations. On the contrary, it's the perfect time to accelerate work and build compliance systems that will ensure security for years to come.

The European Commission's decision to further delay the EUDR signals to businesses and NGOs that the fight over the regulation's shape continues. Companies that use this time to implement compliance tools and collaborate with suppliers will not only gain a competitive advantage but also make a real contribution to forest conservation, which remains the primary goal of the EUDR.

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Green Reporting supports clients in this process by offering:

• automation of EUDR processes in our system Reporting Assistant,

• risk analysis and geolocation of raw materials,

• development of a compliance strategy and documentation required in TRACES,

• ongoing monitoring of regulatory and interpretative changes.