EUDR Delay and Deadlines: What Changed and When

The EUDR has not been delayed again. It applies from 30 December 2026 to all operators and traders, and from 30 June 2027 to micro and small operators established by 31 December 2024, except for timber products already covered by the EUTR. The EUDR, Regulation (EU) 2023/1115, requires businesses that place cattle, cocoa, coffee, oil palm, rubber, soya or wood products on the EU market, or export them, to show the products are deforestation-free and legal. The EUDR hub explains the rest of the regulation.

1. Current EUDR Deadlines

The EUDR hub sets out who counts as an operator or a trader.

2. EUDR delay status

The EUDR has been postponed twice, and no further postponement has been proposed.

The EUDR entered into force on 29 June 2023 and was due to apply from 30 December 2024. In December 2024, Regulation (EU) 2024/3234 moved application back by 12 months. In December 2025, Regulation (EU) 2025/2650 moved it back by a further 12 months, to the dates above, and changed the obligations of downstream operators and traders. The same amendment required the Commission to review the regulation for further simplification by 30 April 2026.

The Commission published that review on 4 May 2026. It did not reopen the legal text or change the application dates. It made its changes through updated guidance, a delegated act on product scope and an implementing act on the Information System. Some Member States continue to press for a further postponement, but no proposal is before the European Parliament or the Council.

3. EUDR timeline to 2027

• 29 June 2023: Regulation (EU) 2023/1115 enters into force, with application due from 30 December 2024.
• 23 December 2024: Regulation (EU) 2024/3234 is published. Application moves to 30 December 2025, and to 30 June 2026 for micro and small operators.
• 22 May 2025: Implementing Regulation (EU) 2025/1093 sets the first country risk classification.
• 9 July 2025: The European Parliament adopts a resolution objecting to the classification.
• 19 December 2025: Regulation (EU) 2025/2650 is adopted. It enters into force on 26 December 2025.
• 4 May 2026: The Commission publishes its simplification review, with draft acts, updated guidance and an updated FAQ.
• 13 July 2026: The Commission adopts Delegated Regulation (EU) 2026/2102, which amends the product list in Annex I.
• 18 September 2026: The Annex I amendment enters into force.
• 30 December 2026: The EUDR applies to all operators and traders.
• 30 June 2027: The EUDR applies to micro and small operators established by 31 December 2024, except for timber products already covered by the EUTR.

4. EUDR simplification changes

Regulation (EU) 2025/2650 set the current dates and changed the obligations further down the supply chain. Downstream operators and traders no longer submit due diligence statements. A downstream operator or trader that buys from an operator keeps the reference number of the operator’s due diligence statement. It does not have to pass the number to its own customers. Downstream operators and traders that are not micro or small enterprises must register in the Information System and keep their records for five years. Micro and small primary operators in low-risk countries submit a one-off simplified declaration in place of a due diligence statement. The amendment also removed printed books, newspapers and pictures from scope.

Delegated Regulation (EU) 2026/2102 amends Annex I from 18 September 2026. Cattle hides, skins and leather, retreaded and used tyres, vehicle and aircraft seats, some other rubber articles, used goods, waste and samples leave scope. Soluble coffee, frozen cattle tongues and some palm oil derivatives join on 30 December 2027. The EUDR hub lists every product in scope.

5. Country risk benchmarking

Implementing Regulation (EU) 2025/1093 sets the country classification that applies from 30 December 2026. It classes Belarus, Myanmar, North Korea and Russia as high risk, 50 countries as standard risk and all other countries as low risk. The European Parliament’s resolution of July 2025 did not change the list, and Regulation (EU) 2025/2650 kept the benchmarking system.

Products produced only in low-risk countries qualify for simplified due diligence. The operator still collects the required information but does not have to assess or mitigate risk, unless it holds information that points to a risk of non-compliance. Products from standard-risk and high-risk countries need a full risk assessment. The Commission publishes the current list on its Green Forum website.

6. Enforcement from 30 December 2026

At import and export, the operator gives customs the reference number of its due diligence statement, and customs checks it against the Information System. Customs can suspend the release of a consignment and refer it to the competent authority.

Every year, the competent authority in each Member State checks at least 1% of operators sourcing from low-risk countries, 3% from standard-risk countries and 9% from high-risk countries (Article 16). Authorities also open checks on substantiated concerns raised by third parties. A business under check should expect to be asked for its due diligence statements, the geolocation of each plot of land, its supplier and customer details, and the risk assessment and risk mitigation records that support each statement.

Member State penalties include fines with a maximum of at least 4% of total annual EU turnover, confiscation of the products and of the revenue from them, and exclusion from public procurement. The EUDR hub sets out the full list.

7. Steps before the deadline

1. Scope your products. Check each product’s HS code against Annex I and identify your role: operator, downstream operator or trader. For timber imports, the Timber Import Scope Checker gives a first answer.
2. Collect the information. Request the Article 9 information from your suppliers: product description, quantity, country of production, supplier details and evidence of legal production.
3. Secure the geolocation. Obtain the coordinates of every plot of land where the commodity was produced. Start with this step, because it takes longest with most suppliers.
4. Assess the risk. Assess each supply chain against the Article 10 criteria, including the country classification.
5. Mitigate the risk. Where the risk is not negligible, take measures that reduce it to negligible, such as requesting further documents or independent surveys, before placing the product on the market.
6. Submit the statement. The operator submits a due diligence statement in the Information System before placing the product on the market or exporting it. The EUDR hub explains what the statement contains.

DoubleHelix (DX) verifies the supply chain data used in EUDR due diligence: the documents, the geolocation and the systems that produced them. Speak to DX about your EUDR deadline.