EUDR: is a postponement coming?

Anyone trying to prepare for the EU Deforestation Regulation in autumn 2025 needed strong nerves, and ideally a crystal ball. While companies had long been busy digitising supply chains, collecting geodata and training suppliers, Brussels was still debating whether, and for whom, any of it should apply yet.

At the end of September, EU Commissioner Jessika Roswall first hinted that the EUDR might be postponed by another twelve months. The stated reason was the overload of the TRACES information system. Shortly afterwards, at the end of October, the Commission's official proposal followed, and little remained of the loudly announced postponement for everyone.

The Commission proposal at a glance

• Introduction of new categories such as "micro and small primary operator" and "downstream operator"
• Downstream operators and traders no longer submit their own due diligence statements
• Authorities only inspect and sanction from June 30, 2026, while the official EUDR start remains December 30, 2025
• Small and micro enterprises only need to be fully compliant by the end of 2026

In other words: the proposal meant the EUDR would be postponed only for small and micro enterprises. For large and medium-sized companies everything would have stayed on the original timeline: start on December 30, 2025. On closer inspection, though, the loudly voiced demands for a zero-risk category and the first-touch principle were recognisable, at least in outline.

Growing resistance

The proposal immediately came under pressure: several member states and their agriculture ministers pushed for all companies to start later and more realistically. At the EU Agriculture Council meeting in Luxembourg, the discontent was voiced clearly.

The plenary days of November 12–13, November 24–27 and December 15–18 were available for presenting the proposal to Parliament. Only one thing was certain at the time: without an agreement, the EUDR would have become applicable exactly as planned, with all obligations, within a few weeks.

In hindsight we know: the agreement came. Read how it continued in our article on the parliamentary vote of November 27, 2025.