The EU Deforestation Regulation (EUDR) was set to take effect on 30 December 2024, with full enforcement starting 30 December 2025. Its goal: to ensure that key commodities — like cocoa, coffee, soy, palm oil, and timber — entering or leaving the EU market are not linked to deforestation or forest degradation.
But as 2025 approaches, the implementation timeline has hit a snag. In September 2025, the European Commission proposed a possible one-year delay to give companies, smallholders, and EU systems more time to prepare. The news sparked confusion across industries: does this mean companies can pause their EUDR efforts?
Not exactly.
While a delay has been suggested, it’s not yet law. The official enforcement date remains 30 December 2025, and until a formal amendment is passed, companies are still expected to stay on track with due diligence and traceability requirements.
This blog breaks down what the proposed EUDR delay actually means, why it’s being discussed, and — most importantly — what your company should be doing right now to stay ready.
The headlines about an “EUDR delay” have caused understandable uncertainty. Some companies paused their preparations, assuming the regulation’s enforcement would automatically shift. But the reality is more nuanced.
Here’s where things stand today:
The EU Deforestation Regulation officially entered into force in June 2023, and its obligations remain legally binding. That hasn’t changed. What’s under discussion is not the regulation itself, but the timeline for enforcement, particularly for due diligence reporting through the EU’s TRACES platform.
In September 2025, the European Commission signaled a potential one-year delay, suggesting that large and medium-sized companies might have until 30 December 2026 to comply, and smaller companies until June 2027. This proposal came after mounting concerns that the necessary digital infrastructure and Member State systems wouldn’t be ready in time.
However, this announcement came in the form of a letter from the Commission — not a legislative amendment. For any delay to take effect, it must go through the formal EU legislative process, involving the European Parliament and the Council of the EU. Until both institutions approve and publish the amendment in the Official Journal, the legal enforcement date remains 30 December 2025.
The delay proposal primarily stems from technical and operational challenges, not political disagreement with the regulation’s goals.
These issues combined have raised concerns that enforcing EUDR in late 2025 could result in widespread supply chain disruption, particularly for commodities like cocoa, coffee, and palm oil.
The European Commission’s proposal to delay EUDR enforcement didn’t appear out of nowhere. It’s the result of mounting operational and political pressure from EU Member States, producer countries, and industry associations who all agree on one thing: the regulation’s objectives are essential, but the systems supporting it may not be ready in time.
Below are the key reasons driving the discussion around postponement.
At the center of the discussion is the TRACES system, the EU’s online platform where companies will need to upload their due diligence statements. This digital infrastructure will serve as the central database for verifying compliance across all affected commodities — cocoa, coffee, soy, palm oil, rubber, cattle, and timber.
However, the platform’s development has faced repeated delays. As of late 2025, TRACES is still undergoing testing, with limited functionality and performance challenges. Many companies have not yet been able to run full-scale submissions, and several Member States have warned that the system might not be ready to handle the expected data load once enforcement begins. If implemented prematurely, it could cause severe bottlenecks, blocking compliant shipments or overwhelming customs authorities.
Another challenge lies in the different speeds at which Member States are preparing for EUDR enforcement. Countries such as the Netherlands, Germany, and Denmark are relatively advanced — training their competent authorities and establishing enforcement systems — while others are still defining responsibilities and operational procedures.
Without consistency, companies trading across borders face uncertainty. A shipment that passes inspection in one Member State could be delayed or rejected in another simply because of varying interpretations of the regulation. This patchwork approach risks undermining both confidence and fairness within the single market.
The readiness gap is even wider in sourcing countries. Many producers are unprepared for the data and documentation requirements that EUDR demands. Providing exact geolocation coordinates, verifying land ownership, and maintaining traceability from farm to export are enormous challenges, especially in regions where recordkeeping is largely paper-based.
Exporters depending on thousands of small farms, are finding it nearly impossible to consolidate compliant data in time. These barriers raise serious concerns about market exclusion, as smallholders risk being cut off from EU trade simply because they lack the digital infrastructure to prove compliance.
There is also a growing fear that rushing enforcement without adequate preparation could disrupt global trade. If importers fail to submit valid due diligence statements by the 2025 deadline, shipments could be delayed or rejected at EU ports, causing financial losses and logistical backlogs. For commodities like cocoa, coffee, and palm oil — which rely on long, fragmented supply chains — even small disruptions can have ripple effects on pricing and availability.
Industry associations, NGOs, and several Member States have urged the European Commission to consider the operational risks of an untested rollout. A short delay, they argue, could help prevent widespread disruption while still maintaining the regulation’s core purpose.
Even if the EUDR deadline is postponed, the direction of travel is clear: deforestation-free supply chains are here to stay. Whether enforcement starts in 2025, 2026, or later, the due diligence requirements — geolocation mapping, traceability documentation, and risk assessments — will remain the same.
That means companies who keep moving now won’t lose any effort; they’ll simply be better prepared when the regulation fully takes effect.
Here’s how to make smart progress even amid uncertainty.
Gathering and validating supplier data remains your top priority.
Your teams should know how EUDR data flows through your business.
Suppliers — especially smallholders — need clear guidance now, not later.
Treat this as a rehearsal for full enforcement.
The timeline may shift, but you need to know when and how.
Whether or not the EUDR timeline shifts, the regulation’s essence remains unchanged: every company placing affected commodities on the EU market must prove that their supply chains are deforestation-free, legally compliant, and fully traceable. That proof depends entirely on the quality of data collected — and how consistently it’s maintained. Building that foundation now ensures a smoother path to compliance later.
At the heart of EUDR compliance lies geolocation. Every farm or production plot connected to your supply chain must have precise GPS coordinates to demonstrate that no deforestation occurred after 31 December 2020. This means going beyond general sourcing regions and pinpointing exact plots, boundaries, and land sizes.
For companies working with smallholders or cooperatives, this can be a major challenge. Many producers operate without digital mapping tools or consistent recordkeeping. The solution often lies in partnerships — engaging local cooperatives, NGOs, or digital mapping platforms to help farmers collect accurate location data in standardized formats such as shapefiles or polygons.
To connect the dots between a physical product and its origin, companies need transparent production and harvest data. Each batch or shipment should be traceable to a particular harvest season, farm, and supplier. This step verifies that the product was grown on compliant land and harvested within an approved time frame.
For example, a cocoa trader exporting to the EU must be able to show that beans sourced in 2024 came from plots that were cultivated well before the deforestation cutoff date. Without that documentation, even compliant products could face delays or rejection once enforcement begins.
The EUDR doesn’t just target deforestation — it also requires proof that commodities were produced legally according to the national laws of the country of origin. That means collecting and maintaining valid land-use rights, business or farming licenses, and documentation related to labor, tax, and environmental compliance.
This can be particularly complex for suppliers in regions with overlapping land claims or informal ownership systems. Translating and verifying these documents early, ideally through local authorities or certified intermediaries, helps prevent future disputes and ensures your due diligence file meets EU expectations.
Once traceability data is collected, companies must conduct risk assessments to evaluate the likelihood of deforestation or legal non-compliance. Each supplier and sourcing region should be categorized as low, medium, or high risk based on deforestation rates, governance quality, and evidence of mitigation measures.
This isn’t just an internal exercise — the results of your assessment feed directly into your Due Diligence Statement (DDS), which will be submitted via the EU’s TRACES platform. Documenting your risk analysis and mitigation steps in detail now will make it easier to complete your DDS later.
EUDR compliance isn’t a one-time project. Companies must keep all due diligence records for at least five years after products are placed on the market. That means every document, update, and supplier correction needs to be stored securely, time-stamped, and versioned.
A well-structured document management system — whether in-house or through a compliance platform — helps ensure your records remain audit-ready. This is especially important for suppliers updating information frequently, such as switching farms, expanding plots, or renewing certifications.
A possible EUDR delay might buy companies more time, but it doesn’t change what’s expected. The core obligations — due diligence, traceability, and documentation — remain the same. The difference will come down to how efficiently you use this time to prepare.
The companies that start now will be the ones ready when enforcement begins. Those already collecting supplier data, verifying sourcing details, and building a system for documentation won’t need to rush when deadlines shift — they’ll simply keep updating what’s already in place.
