EUDR current status: delay, latest news, deadlines and what applies when

As at 9 October 2026. This page is updated on an ongoing basis. The change log is at the end of the page.

Has the EUDR been delayed? Yes, twice, by one year each time. The date of application is 30 December 2026; for micro and small enterprises and natural persons it is 30 June 2027, subject to the conditions set out below. As at 9 October 2026, EUR-Lex lists no proposal that changes these dates. Details are in the section EUDR delay: what applies now.

On the EU Deforestation Regulation, there is currently movement on three fronts at once: the delegated act on product scope has appeared in the Official Journal and has been in force since 18 September, the German implementing act is before the Bundestag, and the date of application for large and medium-sized enterprises is now just under 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 where things stand on a further postponement.

In brief

Regulation (EU) 2023/1115 has been in force since 29 June 2023 (Article 38(1)). It was last amended by Delegated Regulation (EU) 2026/2102 on Annex I and, before that, 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 laid down in Article 38 of the Regulation; as at 9 October 2026, EUR-Lex lists no proposal that changes them. In May 2026 the Commission stated that it does not consider it appropriate to propose further amendments to the basic legal text and that it is focused on ensuring a successful entry into application by 30 December 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 government bill for the implementing act has been before the Bundestag since 30 September 2026 (printed paper 21/8278); the act is due to enter into force on 30 December 2026.

Two things are currently open: the parliamentary process for the German act and the Commission proposal to exclude French Guiana from the scope. The product scope has been settled since 17 September 2026.

EUDR delay: what applies now

The EUDR has been delayed twice, by one year each time. The date of application is 30 December 2026; for natural persons and micro and small enterprises that are operators and were established as such by 31 December 2024 it is 30 June 2027, except for timber and timber products covered by the Annex to the EU Timber Regulation. As at 9 October 2026, EUR-Lex lists no proposal that changes these dates. It records three proposals to amend the Regulation: two were completed with the two postponements, and the third (COM(2026) 661) concerns French Guiana only.

Under Article 34(1a), the Commission had to present a simplification report by 30 April 2026, accompanied, where appropriate, by a legislative proposal. In its report of 4 May 2026 (COM(2026) 191) it states that it does not consider it appropriate to propose further amendments to the basic legal text. The next general review of the Regulation is due by 30 June 2030.

In all three versions, the later date did not apply to timber and timber products covered by the Annex to the EU Timber Regulation. The reference date for qualifying as a micro or small enterprise was initially 31 December 2020; since the second postponement it has been 31 December 2024, and the later date also covers natural persons. The Commission presented the second amending proposal in October 2025. By its own account, the aim was to reduce the strain on the IT system and the administrative burden.

The countdown

Just under 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, some of the 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 applies to me?

For most companies the date is 30 December 2026. The deferral to 30 June 2027 is available only to operators already established as a micro or small enterprise or as a natural person on 31 December 2024, and not for timber covered by the Annex to the EU Timber Regulation. Find your role and your company size in the table; size is determined under Accounting Directive 2013/34/EU.

A company with 180 employees and EUR 40 million in turnover is a medium-sized enterprise; if it acts as an operator, full due diligence applies from 30 December 2026. If you cannot place yourself in the table with confidence, the EUDR check classifies your product by its customs tariff number and gives you your role, date and obligations. The roles are explained in detail in Trader or operator? EUDR roles, SME thresholds and deadlines.

EUDR news 2026: what has happened

Since 18 September 2026 the new Annex I has applied, on 23 September 2026 the Commission revised its TARIC working document, and since 30 September 2026 the bill for the German implementing act has been before the Bundestag. The most recent item comes first; each entry states the event and what it means for companies.

October 2026: The Commission is offering six online training sessions on the information system, each at 14:00 Brussels time: on 6, 13 and 22 October for upstream operators on submitting due diligence statements, and on 8, 15 and 27 October for micro and small primary producers on simplified declarations. Registration is via the Commission's information system page.

What this means: If you have not used the information system yet, these sessions are a guided way to get to know it before live operation.

30 September 2026: The Federal Government introduces the draft implementing act in the Bundestag as Bundestag printed paper 21/8278 (in German). The draft names the Federal Office for Agriculture and Food (BLE) as the competent authority, with the Länder authorities responsible for primary production and timber harvesting in Germany, and allows the BLE to delegate its own tasks to private legal entities. As sanctions it provides for prison sentences of up to five years, up to ten years for severe, long-lasting environmental damage, and fines of up to EUR 100,000; legal persons with total turnover above EUR 500,000, EUR 1.25 million or EUR 2.5 million can, depending on the breach, be fined up to 4 per cent of their EU-wide total turnover. The act is due to enter into force on 30 December 2026. All of this is a draft, not law in force. The printed paper also contains the Federal Government's reply to the Bundesrat's opinion.

What this means: The act does not change the obligations, which apply directly under the Regulation. Sanctions and inspection powers in Germany are still open, and the draft does not apply until the act is promulgated.

25 September 2026: The Bundesrat delivers its opinion on the draft implementing act (Bundesrat printed paper 438/26 (decision)).

What this means: None of the Bundesrat's points changes the obligations under the Regulation. Most of them aim at relief and milder sanctions; in its reply, the Federal Government rejects the majority and will examine two. Details under What is currently open.

23 September 2026: revision 1 of the TARIC data. The Commission publishes a revised version of its working document on the TARIC codes for the Regulation. Code C717 has a new description and now stands for the simplified declaration of micro and small primary producers. New codes include C720 and C725 for re-imports by downstream operators and Y188 and Y196 for their exports, in each case split between SMEs and non-SMEs. Y141 for operators using the deferral to 30 June 2027 remains valid and can be declared until 29 June 2027.

What this means: Anyone preparing customs declarations or configuring a customs system should check their code table against this revision. Overviews from the summer may still describe some codes differently. All codes are explained in EUDR TARIC codes: C716, C717, C720, Y129, Y132, Y188, Y196.

18 September 2026: the new Annex I applies. Delegated Regulation (EU) 2026/2102 enters into force. Cattle hides and leather, retreaded tyres, soya beans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats leave the scope. 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, items of correspondence, packaging material used to support, protect or carry another product, and marketing and information material exclusively accompanying another product or supplied free of charge, among other things, are expressly not covered. Packaging sold as a product in its own right remains covered.

What this means: Any scope assessment now has to be based on the new Annex. If you only source products that have been removed, you can stop preparing for them. If you source newly added products, you have a year longer, but the geolocation data needs the same lead time as everyone else's.

17 September 2026: The European Parliament and the Council raised no objection during the two-month scrutiny period. Delegated Regulation (EU) 2026/2102 on Annex I is published in the Official Journal.

What this means: The product scope is settled. Customs tariff classifications that were carried as provisional can now be frozen.

10 September 2026: The Commission proposes to remove French Guiana from the territorial scope of the Regulation (COM(2026) 661). Details under What is currently open.

What this means: Until the Council decides, the Regulation applies there unchanged. For trade with the rest of the EU it would remain fully applicable even afterwards.

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 this means: The act governs competent authorities, inspections and sanctions in Germany, not the obligations themselves. The cabinet decision started the legislative procedure.

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

What this means: Teams using the information system for the first time can get started before live operation. The current dates are in the October entry.

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

What this means: For contested points of interpretation there is a published Commission position in German. The guidelines are not binding, but authorities align with them.

13 July 2026: The Commission adopts two legal acts: the delegated act on Annex I and Implementing Regulation (EU) 2026/1565. The latter governs the information system, including the submission of the simplified declaration for micro and small primary producers introduced by Regulation (EU) 2025/2650, and updates the API specifications.

What this means: Anyone building or buying an interface to the information system has had a binding basis since July. Integrations built earlier have to be checked against it.

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.

What this means: Registration and test runs are possible; doing both before December takes the least effort.

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.

What this means: In the report, the Commission expressly does not consider further amendments to the basic legal text appropriate. The watch list further down tracks the status of a possible third postponement.

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; they collect and store information, and those that are not SMEs must also register and check where there are substantiated concerns.

What this means: The dates that apply today come from this regulation, as does the cut-off date of 31 December 2024 for the deferral for small enterprises. Downstream actors no longer submit a due diligence statement of their own.

December 2024: Regulation (EU) 2024/3234 postpones the original date of application of 30 December 2024 by one year.

What this means: Overviews from that period still show 30 December 2025 and, as the cut-off date for small enterprises, 31 December 2020; both dates have been superseded.

What is currently open

The delegated act on Annex I is done. Neither the European Parliament nor the Council raised objections within the two-month period under Article 35(6) of the Regulation. The Commission published the act on 17 September 2026 as Delegated Regulation (EU) 2026/2102 in the Official Journal; under its Article 2 it enters into force the day after publication, so on 18 September 2026.

For practical purposes, this means: the new Annex I applies. If you have been carrying HS code classifications with a provisional flag, you can freeze them now. If you buy leather or retreaded tyres, you can stop preparing for them; if you buy soluble coffee or palm oil derivatives, start the supplier communication now, even though those products are only covered from 30 December 2027. The full list with the check procedure is in Which products and customs tariff codes fall under the EUDR.

The German implementing act. Since 30 September 2026 the Federal Government's bill has been before the Bundestag (printed paper 21/8278). 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. In its reply to the Bundesrat's opinion, the Federal Government rejects most of the requested changes, including fines for intent only; it will examine two points, among them limiting sales bans to serious and repeated infringements. Competences, check rates, fines and penalties under the bill are explained in EUDR enforcement in Germany: BLE checks, fines and penalties. This does not alter the obligations under the Regulation itself, because they are directly applicable.

The Bundesrat's statement. On 25 September 2026 the Bundesrat, the chamber of the German federal states, delivered its statement on the draft act (Bundesrat printed paper 438/26 (decision)). Most of its points aim at relief and milder sanctions: fines only for intentional breaches; for a first breach, a fine only if a corrective action ordered by the authority has not been carried out within the deadline set, except for serious or repeated breaches; no administrative offence if the information system fails and the emergency procedures were followed; no criminal liability for insignificant quantities; a temporary ban on placing on the market only for serious and repeated breaches. It also wants the Federal Office for Agriculture and Food (BLE) rather than the federal states to check cattle and soy producers in Germany, and forestry associations to be able to submit one simplified declaration for their members. These are requests, not law in force; whether the Federal Government and the Bundestag adopt them is open. None of them changes the obligations under the Regulation.

French Guiana to be excluded. On 10 September 2026 the Commission proposed excluding French Guiana, including its customs territory, from the territorial scope of the Regulation (COM(2026) 661, procedure 2026/0261(CNS)). The proposal is part of a package for the outermost regions; it is adopted by the Council after consulting the European Parliament. Exempt would be products produced in French Guiana and sold there or exported to third countries, and goods from third countries placed on the market there. For trade with the rest of the EU the Regulation would continue to apply in full: products moved from French Guiana to be placed on the market elsewhere in the Union are treated as entering the Union market and need a due diligence statement or simplified declaration; products going the other way are treated as leaving it. Until a decision is taken, the Regulation continues to apply in French Guiana unchanged.

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

Just under 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. The changes made by Delegated Regulation (EU) 2026/2102 are binding from 18 September 2026.

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 happens if you are not ready on 30 December

There is no transitional period and no grace period. From the date of application, relevant products may only be placed on the market, made available on the market or exported if a due diligence statement or a simplified declaration exists for them (Article 3 of the Regulation).

At the border. Without a due diligence statement there is no reference number. From 30 December, the customs declaration for relevant goods requires the reference number with code C716, for micro and small primary producers the declaration identifier of the simplified declaration with code C717, or a matching exemption code. If none of these is given, the declaration is incomplete and, according to the Commission's TARIC working document, the import is not permitted. The goods stay in the port or in a customs warehouse, and demurrage and storage costs run from day one.

Inside the single market. Here too, making goods available is unlawful if no statement was submitted for them or if the downstream company lacks the required information. Because goods produced or resold within the EU do not pass through customs, this only surfaces later: during an inspection by the competent authority, through substantiated concerns raised by third parties, or because a customer asks for the reference number and does not get it. In the last case the order may be lost before any authority hears about it.

Stock from before the date. Goods placed on the EU market before 30 December 2026 may still be resold and processed afterwards. The companies further down the chain then have to be able to show that the goods were placed on the market before that date (Commission FAQ version 5, question 9.1). Special rules apply to timber under Article 37(2) of the Regulation.

How likely an inspection is. Each year, authorities inspect at least 1 per cent of operators for low country risk, 3 per cent for standard risk and 9 per cent for high risk, plus 9 per cent of the quantity of each product in the high-risk case (Article 16). They select on a risk basis, and downstream operators and traders that are not SMEs count as well. Not every consignment is checked.

What sanctions Germany plans. The Federal Government's bill for the implementing act (printed paper 21/8278 of 30 September 2026), which is before the Bundestag, provides for:

• Administrative fines, for legal persons above certain turnover thresholds up to 4 per cent of EU-wide total turnover in the financial year preceding the authority's decision (section 14)
• Imprisonment of up to five years or a criminal fine for placing on the market, making available or exporting contrary to Article 3 of the Regulation; up to three years where the conduct is grossly negligent; one to ten years for severe, long-lasting environmental damage; insignificant quantities are exempt from criminal liability except in cases of severe environmental damage (section 12)
• Confiscation of the commodities and products concerned (section 15)
• After a conviction or a final fine: exclusion from public contracts and public funding (after a final conviction or a fine of at least EUR 5,000), and a ban on placing on the market, making available or exporting relevant commodities or products as well as suspension of the simplified procedure under Article 13 (after a conviction, a fine of at least EUR 10,000 or repeated fines), each for up to one year (section 16)

The 4 per cent ceiling is not a German addition. Article 25(2) of the Regulation requires every Member State to set the maximum fine for legal persons at no less than 4 per cent of annual EU-wide turnover, and to raise it where necessary so that it exceeds the potential economic gain. The criminal offences also implement the environmental crime directive (EU) 2024/1203. Until the act is promulgated the draft does not apply, and changes during the legislative procedure are possible. Details are in EUDR enforcement in Germany: BLE checks, fines and penalties.

If there is not enough time. Work through these steps in this order:

1. Which of your products fall under the new Annex I? The customs tariff number decides, not the invoice description.
2. Which of those do you import or first place on the EU market yourself? There, due diligence sits with you and not with your supplier in a third country.
3. Request geolocation data and evidence for exactly those products from your suppliers. They need lead time, so ask as soon as points 1 and 2 are clear.
4. Register in the information system and rehearse submitting a statement once. This is the part that has to work on the day.

Where you are a downstream operator or trader, the work is quickest to complete: you do not submit a statement of your own, you record suppliers and customers and, as the first buyer after the operator, also the operator's reference numbers, and you register if you are not an SME.

Third postponement: status and assessment

The question of a further postponement is the one asked most often. As at 9 October 2026, EUR-Lex lists no proposal that changes 30 December 2026 or 30 June 2027. In its report of 4 May 2026 the Commission states that it does not consider it appropriate to propose further amendments to the basic legal text. It refers to the need to preserve legal certainty and ensure a stable and predictable regulatory framework for economic operators, and to the progress made in reducing compliance costs. According to the Commission, the simplification package of May 2026 responds to the concerns of stakeholders. Calls for further relief continue; according to press reports from early October 2026, the United States and Canada are pressing for lighter traceability and documentation requirements for timber from countries with a low risk of deforestation.

Changing the date of application requires a Commission proposal, which the European Parliament and the Council then have to adopt under the ordinary legislative procedure. Both postponements so far were based on a Commission proposal made in October (2 October 2024 and 21 October 2025). The amending regulations of the European Parliament and of the Council are each dated 19 December, eleven days before the date of application then in force. A few places therefore show whether anything is still moving.

Watch list: how you would recognise a third postponement

The German implementing act cannot postpone the European deadlines, even though the two are often confused. It governs competent authorities, inspections and sanctions in Germany. The obligations apply directly under the Regulation, even if the act has not been promulgated by 30 December 2026.

In our assessment, 30 December 2026 is the date to plan for as long as there is no Commission proposal. The later such a proposal came, the less time the European Parliament and the Council would have before the deadline. 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 October 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. As at 9 October 2026, EUR-Lex lists no proposal that changes these dates.

Will the EUDR be delayed again in 2026?

As at 9 October 2026, EUR-Lex lists no proposal that changes 30 December 2026 or 30 June 2027. The only open proposal to amend the Regulation listed there, COM(2026) 661, concerns French Guiana. In its report of 4 May 2026 the Commission stated that it does not consider it appropriate to propose further amendments to the basic legal text. Both postponements so far were regulations of the European Parliament and of the Council.

Which EUDR deadlines apply now?

Three dates. From 30 December 2026 the Regulation applies to large and medium-sized enterprises. From 30 June 2027 it applies to natural persons and micro and small enterprises 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. From 30 December 2027 it applies to the products newly included in Annex I.

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?

Done. Neither the Parliament nor the Council raised objections; the Commission published it on 17 September 2026 as Delegated Regulation (EU) 2026/2102 in the Official Journal. It has been in force since 18 September 2026. 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.

What happens if I do not have a due diligence statement on 30 December 2026?

Then, as an operator, you may not place the goods concerned on the market, make them available on the market or export them. On importation, without a reference number or a matching exemption code the customs declaration is missing a required entry; the import is then not permitted, and demurrage and storage costs arise. Inside the single market, making goods available without a statement remains unlawful and can be penalised during an inspection or after substantiated concerns. Goods placed on the EU market before 30 December 2026 may be resold with evidence of that date. There is no transitional period for companies that are not ready. For micro and small enterprises and natural persons already established as such on 31 December 2024, this applies only from 30 June 2027, except for timber covered by the Annex to the EU Timber Regulation.

Is my supplier liable if the geolocation data is wrong?

That depends on who places the goods on the EU market. If you import or first place them on the market yourself, due diligence sits with you and not with your supplier in a third country. You have to check your supplier's information rather than simply pass it on: whether the geolocation data is plausible, where the information comes from, and the risk of mixing and circumvention. If the data turns out to be wrong, your company carries the responsibility; damages and evidence obligations can be agreed by contract, but that does not shift the public law duty. If, on the other hand, you buy from an operator in the EU that has submitted a due diligence statement, that operator assumes responsibility (Article 4(3) of the Regulation); you are then a downstream operator or trader.

Change log

9 October 2026: Clarified the summary: the Regulation has been in force since 29 June 2023 and was last amended by Delegated Regulation (EU) 2026/2102 on Annex I, before that by Regulation (EU) 2025/2650. Rechecked EUR-Lex on 9 October 2026. Deadlines, product scope and obligations are unchanged.

8 October 2026: Added the section “What applies to me?” with a table by role and company size. New section “What happens if you are not ready on 30 December” covering the consequences at the border and in the single market, inspection rates and the sanctions under the bill (printed paper 21/8278). Added a watch list on a third postponement. The news section now shows the most recent item first, states what each item means and includes the TARIC revision of 23 September 2026. Added two frequently asked questions. Added sign-up for the EUDR newsletter. Added a “Latest developments” box at the top of the page with the position on a further postponement, the five most recent items and the next dates. Brought the summary up to date with the bill before the Bundestag. Removed the paragraph on the zero-risk category: the only documented point is the Bundesrat's request to raise it again in a later review (see the watch list). Rechecked EUR-Lex on 8 October 2026. Status overview (PDF) regenerated as at 8 October 2026. Deadlines, product scope and obligations are unchanged.

7 October 2026: Added the Federal Government's reply to the Bundesrat's opinion and a link to the new article on checks and penalties under the bill. Brought statements on a further postponement into line with the Commission's wording of 4 May 2026; the section “What will not happen” is now called “Third postponement: status and assessment” and also covers calls for further relief. Rechecked EUR-Lex on 7 October 2026. The row on a third postponement in the status overview (PDF) has been corrected accordingly. Deadlines, product scope and obligations are unchanged.

5 October 2026: Added the introduction of the Federal Government's bill in the Bundestag as printed paper 21/8278 of 30 September 2026, with the competent authority and the sanctions framework of the draft. Deadlines, product scope and obligations are unchanged.

30 September 2026: Short answer on the delay at the top of the page and new section “EUDR delay: what applies now” with the history of the two postponements and the amending proposals listed on EUR-Lex. Added the Commission's October 2026 training dates for the information system. Added two frequently asked questions. Deadlines, product scope and obligations are unchanged.

29 September 2026: Added the Commission proposal of 10 September 2026 to exclude French Guiana from the scope of the Regulation (COM(2026) 661). Added the Bundesrat's statement of 25 September 2026 on the German implementing act and a link to the consolidated version of 18 September 2026. Deadlines, product scope and obligations are unchanged.

17 September 2026: The delegated act on Annex I has appeared in the Official Journal as Delegated Regulation (EU) 2026/2102 and enters into force on 18 September 2026. Status table, timeline and charts updated accordingly; the advice to mark HS code classifications as provisional has been removed.

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. Regulation (EU) 2024/3234 of 19 December 2024 (first postponement). Article 34(1a) and (2) and Article 38 of Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650. EUR-Lex, document information on Regulation (EU) 2023/1115 (amending proposals), accessed 30 September 2026, 7 October 2026, 8 October 2026 and 9 October 2026. European Commission, information system page (training dates October 2026), accessed 30 September 2026. Implementing Regulation (EU) 2026/1565. Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 amending Annex I, OJ L of 17 September 2026, in force from 18 September 2026. Commission guidelines, OJ C/2026/3896 of 20 July 2026. Commission FAQ version 5 of 4 May 2026, in particular question 9.1. Commission TARIC working document on Regulation (EU) 2023/1115, revision 1 of 23 September 2026. Evaluation report COM(2026) 191 of 4 May 2026 and Commission press release IP/26/941 of the same day. Proposal for a Council Regulation on the outermost regions, COM(2026) 661 of 10 September 2026 (procedure 2026/0261(CNS)). 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. Statement of the Bundesrat of 25 September 2026, Bundesrat printed paper 438/26 (decision). Government bill of 30 September 2026, Bundestag printed paper 21/8278, in particular sections 12 to 16. German Bundestag, hib press release “Nationale Umsetzung der EU-Entwaldungsverordnung” of 1 October 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. FoodNavigator, “EUDR: Will it be simplified further?”, 5 October 2026. Global Wood Markets Info, “US and Canada press EU to ease EUDR rules for forest products”, 7 October 2026. This article describes the position as at 9 October 2026 and does not replace legal advice.

All EUDR articles

Each article in this series covers one duty in detail. This overview is kept up to date.

• EUDR enforcement in Germany: who checks, what is examined and which penalties apply
• The Commission's EUDR FAQ: which version applies, what version 5 answers anew and what changed in August 2026
• The EUDR for palm oil: what importers, refiners, oleochemicals and food manufacturers have to do now and from 2027
• EUDR for US exporters: what your European customers will need from you from 30 December 2026
• Supplier geodata for the EUDR: requirements, formats, validation, with a template in CSV and GeoJSON
• EUDR for paper and packaging: what pulp importers, paper mills, printers and packaging manufacturers must do by 30 December 2026
• Submitting a due diligence statement in the EUDR Information System: step by step in TRACES and via the API
• The EUDR for rubber: what tyre makers, importers, compounders and the rubber goods trade must do by 30 December 2026
• The EUDR for coffee and cocoa: what importers, roasters, grinders and chocolate makers must do by 30 December 2026
• The EUDR for the timber industry: what forest owners, sawmills, timber traders, furniture and paper makers must do by 30 December 2026
• EUDR TARIC codes: C716, C717, C720, Y129, Y132, Y188, Y196
• The EUDR guide 2026: everything you need to know about the EU Deforestation Regulation
• The EUDR on export, re-import and re-export: which duties apply and which customs codes go into the declaration
• EUDR Annex I and CN codes: how to check whether your product is in scope, and what the 2026 recast changed
• The new EUDR Annex I is in the Official Journal: what leaves the scope tomorrow and what joins it in 2027
• Trader or operator? The four EUDR roles, the SME thresholds and the two deadlines
• The EUDR reference number: format, verification number, sharing along the supply chain and why you cannot apply for one
• EUDR software comparison 2026: 16 providers, prices and which solution fits your role
• The EUDR Information System: Registration, Duties and Current Status 2026
• The EUDR due diligence statement: why there is no template, what Annex II requires and what happens after you submit
• Who is affected by the EUDR in 2026?
• European Parliament votes for postponement and simplifications
• Political deadlock, growing pressure, a tight timeline
• EUDR: is a postponement coming?