EUDR current status: deadlines, the delegated act, the German implementing act and what applies when

As at 8 September 2026. This page is updated on an ongoing basis. The change log is at the end of the page.

On the EU Deforestation Regulation, there is currently movement on three fronts at once: the delegated act on product scope is nearing the end of its scrutiny period, the German implementing act is going to the Bundestag, and the date of application for large and medium-sized enterprises is now a good three months away. If you only read the headlines, you can easily get the impression that everything is still open. It is not.

This page summarises what is in force today, what is currently under way and what is no longer to be expected.

In brief

Regulation (EU) 2023/1115 has been in force since 29 June 2023 and was last amended by Regulation (EU) 2025/2650 of 19 December 2025. The date of application is 30 December 2026 for large and medium-sized enterprises and 30 June 2027 for micro and small enterprises and natural persons that are operators and were established as such by 31 December 2024; for timber and timber products already covered by the EU Timber Regulation, 30 December 2026 applies to them as well. These dates are fixed; the Commission has repeatedly ruled out a further postponement and expressly confirmed this in May 2026.

The simplification package of May 2026 and the legal acts of July 2026 have noticeably reduced the obligations, above all for downstream companies, but have not abolished them. The information system has been available again since the end of June 2026. In Germany, the implementing act has had the status of a Federal Cabinet decision since 12 August 2026 and is due to enter into force on 30 December 2026.

Three things are currently open: the end of the scrutiny period for the delegated act on Annex I, the parliamentary process for the German act and the zero-risk category at EU level that the German Federal Government is seeking.

The countdown

A good three months remain until the date of application for large and medium-sized enterprises. For procurement, that is less than it sounds: with the usual lead times of two to four months, goods ordered now will not arrive until the Regulation is already applicable. These deliveries need a due diligence statement, and it has to come from the company that places them on the market.

An important point of context: medium-sized enterprises get no deferral. The extended deadline of June 2027 applies only to micro and small enterprises within the meaning of the Accounting Directive and to natural persons, and even then only insofar as they are operators. What counts is the position on 31 December 2024: an enterprise established as a micro or small enterprise only after that date is also bound from 30 December 2026. For timber and timber products already covered by the EU Timber Regulation (EU) No 995/2010 there is no deferral: here, 30 December 2026 applies to micro and small enterprises as well. Which thresholds apply and how the roles interact are explained in Trader or operator? EUDR roles, SME thresholds and deadlines.

What happened in 2026

19 December 2025: Regulation (EU) 2025/2650 amends the EUDR under the ordinary legislative procedure. It postpones the date of application for a second time and introduces the distinction between upstream and downstream operators. Since then, downstream actors no longer have to exercise due diligence of their own, but only have to collect and store information.

4 May 2026: The Commission presents its review package: an evaluation report on the simplifications (COM(2026) 191), a new version of the FAQ (version 5), updated guidelines, a revised EU implementing act on the information system and a draft delegated act on Annex I. The core message: the deadlines remain in place, and the obligations are not being weakened any further.

End of June 2026: The EU information system is made available again, and further functions follow over the summer. For details, see TRACES and the EU information system: login, test system, API and geolocation data.

13 July 2026: The Commission adopts two legal acts. The delegated act amends Annex I: cattle hides and leather, retreaded tyres, soya beans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats are removed; soluble coffee, certain palm oil derivatives and frozen bovine tongues are added, but are only covered from 30 December 2027. Waste, second-hand goods, samples, packaging material, promotional material and correspondence, among other things, are expressly not covered. Implementing Regulation (EU) 2026/1565 governs the information system, introduces the simplified declaration for micro and small primary producers and updates the API specifications.

20 July 2026: The third version of the guidelines is published in German in the Official Journal (C/2026/3896).

End of July 2026: The Commission launches training sessions for companies.

12 August 2026: The Federal Cabinet adopts the draft of an act reorganising the law on deforestation-free products. Its core, in Article 1, is the German implementing act, the Gesetz zur Durchführung der EU-Verordnung für entwaldungsfreie Produkte (Entwaldungsfreie-Produkte-VO-DurchführungsG), previously known by the working title Entwaldungs- und Waldschädigungs-Minimierungs-Gesetz (EntwaldungsMG). It is intended to implement the Regulation on a one-to-one basis and is due to enter into force on 30 December 2026.

What is currently open

The delegated act on Annex I. Under Article 35(6) of the Regulation, a delegated act enters into force only if neither the European Parliament nor the Council raises objections within two months. This period has been running since 13 July 2026 and therefore ends in mid-September; it can be extended by two months at the initiative of either institution. An objection requires a qualified majority and is unlikely in the case of an act that predominantly narrows the scope. Until publication in the Official Journal, however, the existing Annex I remains in force.

For practical purposes, this means: treat the new Annex I as effectively decided, but formally not yet in force. If you are preparing HS code classifications, mark the changes as provisional and freeze them only after publication. If you source leather or retreaded tyres, you should put the preparatory work for these on hold, but start communicating with your suppliers about soluble coffee and palm oil derivatives. The complete list, including the checking logic, is set out in Which products and customs tariff numbers fall under the EUDR.

The German implementing act. After the Federal Cabinet decision, the implementing act moves into the parliamentary process. Several associations, including some from the skilled crafts sector and forestry, have called for amendments, in particular to the criminal and administrative fine provisions and to the rights of entry and rights to information. Whether the Bundestag will make any changes in this regard is an open question. This does not alter the obligations under the Regulation itself, because they are directly applicable.

The zero-risk category. At EU level, the German Federal Government is advocating a negligible-risk category, which is intended to further reduce the burden for commodities from qualifying countries of production. This is a political objective, not law in force, and could be implemented no earlier than in a future amendment to the Regulation. Do not plan on it.

Which legal act is currently valid

If you are assessing the EUDR today, you are working with six documents. Not all of them are binding, and not all of them are up to date.

A tip that will save you time: the old FAQ version 1.4 is still in circulation and is quoted in many guides. It is outdated in several places, including on how reference numbers are passed on. For every source, check the version before you rely on what it says. The current position on the reference number is set out in EUDR reference number: structure, verification number and passing it on.

Germany: who carries out checks and how

The implementing act divides implementation between two levels. The authorities of the federal states (Länder) supervise primary production in Germany, meaning businesses that place on the market soya they have grown themselves, live cattle from their own holding or wood harvested in Germany. Everything else lies with the Federal Office for Agriculture and Food (BLE), including checks on trade and on the processing industry.

The draft general administrative regulation (AVV) of July 2026 sets out in more detail how the Länder carry out supervision and contains relief for domestic forestry and agriculture: checks are risk-based and rely primarily on the statements and declarations submitted and on existing administrative data. For operators that themselves produce in Germany, existing information on their plots of land and how they are managed is recognised as a due diligence system; a separate risk management system is not required because Germany is classified as a low-risk country. For one-off simplified declarations, the postal address of the holding together with a national identification number is sufficient.

For importing and processing companies, this changes nothing. They are checked by the BLE, and their obligations arise directly from the Regulation.

What to do now

Three months are enough if you use them, and too short to spend waiting.

Check scope. Which of your articles fall under Annex I? The check is based on the customs tariff number, not on the invoice description. Mark the changes made by the delegated act as provisional.

Determine roles. Operator, downstream operator or trader, for each supply relationship and product. This determines whether you submit a due diligence statement or only collect information.

Register. Operators and downstream non-SMEs must register in the information system before they place products on the market or make them available on the market. This takes time and should not be left until December.

Obtain geolocation data. The most common reason companies run into trouble in December is missing or invalid geolocation data for the plots of land where the commodities were produced. Procurement of this data from suppliers in third countries takes weeks to months, and validation in the system often fails at the first attempt.

Carry out a test run. Run a statement through the system before it counts. Also build in lead time, because authorities may delay making the reference number available.

Inform suppliers. If you only ask in December, you will get answers in January.

What will not happen

The question of a further postponement is the one asked most often, so to be clear: there is currently no proposal, no majority and no procedure that would postpone 30 December 2026 once again. The Commission expressly confirmed in May 2026 that the deadlines stand, and the simplification package was the political response to criticism from the business community. There have been two postponements, in December 2024 and in December 2025, both under the ordinary legislative procedure and both with considerable lead time. Nothing of the kind is currently in preparation.

If you base your planning on a third postponement, you are taking a risk that cannot be hedged.

How Polygon One helps

Polygon One maps EUDR due diligence from the collection of geolocation data to the submission of the due diligence statement in the EU information system: a supplier portal for geolocation data and documents, satellite-based deforestation analysis, risk assessment, document review and submission, including retrieval of the reference number and verification number. We incorporate changes in the legal position into the platform, so that you do not have to check every version of the FAQ yourself.

What the platform does not do: assess the legal position in your individual case or determine your role. If you would like to see how far you can get with your data in time for December, book a demo or read on at the product page for the EUDR module.

Download the status overview

One page with all legal acts, their status, the three dates of application and the open issues, with an as-at date, to pass on to purchasing, legal and management.

• Download: EUDR status overview, as at 8 September 2026 (PDF)

Frequently asked questions

Has the EUDR been postponed?

Twice, most recently in December 2025. Since then, the following applies: 30 December 2026 for large and medium-sized enterprises and 30 June 2027 for micro and small enterprises and natural persons that are operators and were established as such by 31 December 2024, except for timber and timber products already covered by the EU Timber Regulation. No third postponement is being prepared.

When does the EUDR enter into force?

It has been in force since 29 June 2023. It becomes applicable on 30 December 2026 and 30 June 2027 respectively. Entry into force and the date of application are two different things.

Is the EUDR mandatory?

Yes. It is directly applicable in all Member States. The German implementing act only governs competent authorities, checks and penalties, not the obligations themselves.

What is the status of the delegated act on Annex I?

Adopted by the Commission on 13 July 2026 and, since then, in the two-month scrutiny period of the European Parliament and the Council. If no objection is raised, it enters into force after publication in the Official Journal. The newly added products are only covered from 30 December 2027.

What does implementation in Germany look like?

The German implementing act (Entwaldungsfreie-Produkte-VO-DurchführungsG, former working title EntwaldungsMG) was adopted by the Federal Cabinet on 12 August 2026 and is currently being considered in the Bundestag. It is due to enter into force on 30 December 2026. Responsibility lies with the Federal Office for Agriculture and Food (BLE) and, for primary production in Germany, with the authorities of the federal states (Länder).

Which version of the FAQ is current?

Version 5 of 4 May 2026. Older versions, in particular version 1.4, are outdated in several places.

Does the EUDR also apply to small enterprises?

Yes, from 30 June 2027, insofar as they are operators and were established as micro or small enterprises by 31 December 2024. For small enterprises established later, and for timber and timber products already covered by the EU Timber Regulation, it applies from 30 December 2026. As downstream actors, they have significantly reduced obligations.

Change log

8 September 2026: Page created. Status: delegated act in the scrutiny period, implementing act in the parliamentary process following the Federal Cabinet decision, date of application of 30 December 2026 unchanged.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650. Implementing Regulation (EU) 2026/1565. Delegated act of 13 July 2026 on Annex I (scrutiny period). Commission guidelines, OJ C/2026/3896 of 20 July 2026. Commission FAQ version 5 of 4 May 2026. Evaluation report COM(2026) 191. Draft Gesetz zur Neuregelung des Rechts über entwaldungsfreie Produkte sowie zur Umsetzung von bestimmten Vorschriften der Richtlinie (EU) 2024/1203 über den strafrechtlichen Schutz der Umwelt, Federal Cabinet decision of 12 August 2026 (Bundesrat printed paper 438/26), published by the German Federal Ministry of Agriculture, Food and Regional Identity (BMLEH) on 13 August 2026. Draft general administrative regulation (AVV) on the Entwaldungs- und Waldschädigungs-Minimierungs-Gesetz, as at 21 July 2026. Responses of the Federal Office for Agriculture and Food to the IHK webinar of 21 May 2026. This article describes the position as at 8 September 2026 and does not replace legal advice.