Just a few days ago, the European Commission has proposed a 12-month delay in the implementation of the EU Deforestation Regulation (EUDR). The EUDR, aimed at curbing the EU’s contribution to global deforestation, was originally set to take effect on December 30, 2024.

 

Key Changes in the Proposal

  1. New Implementation Dates: Under the new proposal, the EUDR’s application would be postponed as follows – Large companies: December 30, 2025; Small and micro enterprises: June 30, 2026.

  2. Country Benchmarking Extension: The Commission has also proposed extending the deadline for adopting implementing acts that classify third countries as low, standard, or high risk. The new proposed date for this crucial step is June 30, 2025. The Commission has indicated that a “large majority” of countries worldwide will be classified as low-risk under the EUDR’s country benchmarking system. This classification aims to facilitate due diligence processes for operators and enable effective compliance monitoring by competent authorities.

Alongside the proposed delay, the Commission has published several long-awaited resources to aid in EUDR implementation, including technical guidance documents, updated FAQs, clarifications on key definitions and terms and guidance on risk assessment and mitigation. They also published a stronger international cooperation framework to support global stakeholders.

The Commission’s decision to propose this delay comes in response to a myriad of factors.

Many global partners and stakeholders have expressed concerns about their readiness to comply with the EUDR by the original deadline. This feedback came from various sources:

  • Industry representatives: Companies across supply chains, particularly those dealing with the affected commodities, voiced concerns about the complexity of implementing the required due diligence systems in such a short timeframe.

  • Exporting countries: Nations that export the regulated commodities to the EU, including Brazil, Indonesia, and Canada, have raised diplomatic concerns about the regulation’s potential impact on trade.

  • International organizations: Even the World Trade Organization’s Director-General has voiced concerns about the EUDR’s potential trade implications.


The Commission has acknowledged that implementing a regulation as complex as the EUDR necessitates a transitional period. This recognition stems from several key factors. Firstly, companies require adequate time to fully develop and implement the intricate due diligence systems mandated by the EUDR. These systems are crucial for ensuring compliance and often involve significant changes to existing processes.

Secondly, the entire supply chain, spanning from producers to importers, needs time to adapt to the new requirements and ensure compliance. This adaptation process can be particularly challenging for complex, multi-tiered supply chains that may involve numerous stakeholders across different countries.

Lastly, the additional time provided by the delay allows for the dissemination and thorough understanding of newly published guidance documents and FAQs. These resources are essential for clarifying the nuances of the regulation and helping businesses interpret and apply the EUDR’s requirements correctly. By allowing for this phasing-in period, the Commission aims to facilitate a smoother and more effective implementation of the EUDR across all affected industries and supply chains.

By proposing this delay, the European Commission aims to address these concerns while maintaining the EUDR’s core objectives. The additional time is intended to facilitate better preparation, allow for further engagement with third countries, and ensure a more effective and smooth implementation of the regulation.

For the proposed delay to take effect, it must be approved by the European Parliament and Council. The Commission has urged these bodies to adopt the proposal “by the end of the year,” which leaves a tight timeline for the legislative process.

While this proposed delay offers businesses additional time to prepare for EUDR compliance, it’s crucial to note that the regulation’s core objectives and requirements remain unchanged. Companies should use this potential extension wisely to fine-tune their compliance programs, adopt proper technology solutions that will strengthen their supply chain due diligence processes and engage with suppliers and partners to ensure readiness.

As we await the final decision on this proposed delay, businesses should continue their preparations for the EUDR, leveraging the newly published guidance and resources.