EUDR: the application timeline, and what has changed since 2023

The EUDR (Regulation (EU) 2023/1115) was adopted in 2023 with application scheduled for 30 December 2024. It has been postponed twice, by twelve months each time. This guide gives the timeline as it applies today, and above all what the second postponement changed in the regulation itself — because, unlike the first, it did not merely move a date.

The dates that apply

• 30 December 2026 — general application date: downstream operators, large and medium-sized enterprises.
• 30 June 2027 — an additional six-month period for micro and small enterprises outside the timber sector, provided they were established as such no later than 31 December 2024.

These dates result from Regulation (EU) 2025/2650 of 19 December 2025, which followed Regulation (EU) 2024/3234 of late 2024. Each moved application back by twelve months: 30 December 2024 originally, then 30 December 2025, then 30 December 2026.

What the second postponement changed in substance

This is the point most summaries miss, because they took away from the first postponement that it only affected the timeline. The second is different: Regulation (EU) 2025/2650 changed the very architecture of the obligations.

• Downstream operators no longer file their own due diligence statement. They collect and keep the reference number of the statement filed by the primary operator. This is a major change for a processor or exporter that had organised itself to produce its own DDS for each batch.
• Micro and small primary operators file a single simplified statement, whose reduced content is defined in Annex III of the regulation.
• Downstream operators other than SMEs no longer have a periodic reporting obligation.
• Two new categories appear: micro and small primary operators established in low-risk countries and producing themselves, and downstream operators working on products already covered by a statement.

In other words, an organisation sized before December 2025 to have each link file a DDS is probably doing more work today than the regulation requires.

What has not moved

The core of the regulation has been stable since 2023, and work already under way on it remains valid:

• the seven commodities covered: cattle, cocoa, coffee, palm oil, rubber, soya, wood;
• the cut-off date of 31 December 2020 for no deforestation (Art. 2, point 13);
• retention of statements for five years from their submission (Art. 4(3));
• the principle of plot geolocation, and that of due diligence itself.

Can the date still move?

Yes, and it needs to be stated precisely rather than used as a reason not to give a date. Regulation (EU) 2025/2650 came with a simplification review: the Commission was to submit a report to the Parliament and the Council by 30 April 2026, accompanied where appropriate by a legislative proposal — this is document COM(2026) 191 final of 4 May 2026.

A third amendment therefore cannot be ruled out. But two successive postponements are no reason to wait: each was adopted a few days before the deadline it moved, which leaves a company that had bet on it exactly zero margin if it had not been adopted.

What this postponement does not change for your internal organisation

A postponed deadline should not translate into a pause in preparation, for two practical reasons:

• Recording plot coordinates (see our guide on the due diligence statement) takes time in the field, regardless of the filing date — starting early avoids a bottleneck as the actual deadline approaches.
• Customers further along the chain may require a statement or proof of compliance before the legal date itself, to secure their own timeline — a regulatory postponement does not necessarily push back a contractual requirement set upstream.

Common mistakes

• Confusing the postponement of the application date with the regulation being scrapped — the obligation remains fully in force; only its deadline has moved.
• Believing there was only one postponement. There were two, and the second also lightened the obligations. An internal memo written in 2025 describes an architecture that is no longer that of the text.
• Continuing to have each link in the chain file a DDS when downstream operators now only need to keep the reference number of the initial statement.
• Taking “30 June 2027” as your own deadline without checking both conditions: being a micro or small enterprise outside the timber sector, and having been established as such no later than 31 December 2024.
• Waiting for the new deadline to start recording plots, when this fieldwork cannot be compressed into the final weeks.

Checklist

1. Determine which of the two dates applies to you: 30 December 2026 by default, 30 June 2027 if you are a micro or small enterprise outside the timber sector established before 31 December 2024.
2. Check whether you are a primary or downstream operator — since December 2025, this no longer determines only the content of the statement, but whether you file one at all.
3. Do not interrupt the recording of plot coordinates while waiting for the deadline.
4. Check whether an upstream customer requires early compliance, independently of the legal timeline.
5. Follow up on the simplification review (COM(2026) 191 final) — a third amendment remains possible.

Sources

• European regulation against deforestation and forest degradation, French Ministry for the Ecological Transition — page published on 13 July 2026, application dates and reference of the amending regulation.
• Delay until December 2026 and other developments in the implementation of the EUDR, Access2Markets, European Commission — simplifications introduced by Regulation (EU) 2025/2650.
• Regulation (EU) 2023/1115, EUR-Lex — commodities covered, cut-off date, retention of statements.

Dates verified on 17 August 2026. This regulation has been amended twice in two years: before committing to a compliance plan, confirm the deadline at the source.