Last month, we briefed our clients about the European deforestation regulation (EUDR), which was scheduled to enter into force on 1 January 2026. At the last minute, both the European Council (the Member States) and the European Parliament decided to postpone the application of these new European rules once again.
A brief reminder: the EUDR is an EU regulation requiring market operators to demonstrate that the products they import or export do not contribute to global deforestation. The EUDR applies to seven agricultural commodities (cocoa, palm oil, soy, coffee, timber, rubber and beef), as well as to products derived from them. These include, among others, car tyres, technical rubber goods, leather, furniture, paper, wooden packaging, cosmetics, chocolate and much more (see below).
The EUDR was originally supposed to take effect at the end of 2024, but its application had already been postponed at the last minute to the end of 2025. Now, another postponement has been announced. As things currently stand, the deadline for large and medium-sized companies would shift to the end of 2026, and to the end of June 2027 for small companies.
Why another postponement?
Many companies and some Member States – especially Germany – believe that the EUDR involves too much bureaucratic red tape. They are also concerned about its practical feasibility. In addition, many companies, Member States and customs authorities will not be ready by 1 January 2026 to correctly implement the complex obligations related to due diligence and DDS numbers (see below).
Furthermore, it appears that the central European information system (TRACES NT) is still facing technical problems. This system must process all DDS registrations but is not yet stable enough. There are fears that it could crash under heavy workload.
Obligations under the current EUDR
According to the currently known version of the regulation, every customs declaration for EUDR-covered goods must include a valid DDS number (reference of the due-diligence statement). This DDS number must be requested in advance via the TRACES NT information system and must then be indicated in the customs declaration together with the correct TARIC code.
Still according to the current rules, customs authorities will check the presence and accuracy of the DDS number. If it is missing or incorrect, the release of the shipment may be suspended, with possible administrative or penal consequences.
Purpose of the postponement
The postponement is intended to provide room for a targeted revision of the regulation, during which the Council and Parliament will work with the Commission on a simpler and more workable system.
The revised version of the EUDR is expected by 30 April 2026 at the latest. By that date, the European Commission must propose the desired amendments to the regulation. During this period, businesses and sector organisations will have the opportunity to provide input to help make the rules more practical.
What does this mean for you?
For most of our clients, the EUDR will have little direct impact. Nevertheless, we recommend checking whether your products fall under the regulation and preparing in good time. A full list of products covered by the EUDR can be found in Annex 1 of the regulation.
The list of EUDR‑covered goods remains unchanged for now. An expansion or adjustment may be considered during the revision in spring 2026. However, it is safe to assume that the current seven commodities and their derivatives will remain subject to the rules.
So make use of this postponement to prepare yourself thoroughly, and be sure to consult the list of derived products to avoid unpleasant surprises.
We will of course keep you informed as soon as the new rules are definitively known.
