EUDR Regulation postponed – what does the deferral mean for businesses?
20 January 2026
The EUDR Regulation – the EU’s anti-deforestation regulation – has once again been postponed. Originally scheduled to come into effect on 30 December 2025, the deadline has been extended by EU institutions for another year. The EUDR Regulation will now apply as of 30 December 2026, while micro and small enterprises will have an additional six months to comply with the new requirements. For companies, this means more time to prepare, but also prolonged regulatory uncertainty, which may impact investment and strategic decisions.
EUDR Regulation – what is it and what is its objective?
The EUDR Regulation (EU Deforestation Regulation) is one of the EU’s most ambitious legal acts in the field of sustainable development. Its aim is to reduce global deforestation and forest degradation by eliminating from the EU market any products whose production contributed to forest destruction after 31 December 2020.
Although the EUDR Regulation formally entered into force in June 2023, its application was deferred to give businesses time to adapt to the new obligations. The regulation covers both placing goods on the EU market and exporting them outside the European Union.
What products are covered by the EUDR Regulation?
The scope of the EUDR Regulation is clearly defined and applies to seven key raw materials and derivative products that historically have had the greatest impact on deforestation:
- timber and timber products
- cocoa
- coffee
- palm oil
- soy
- rubber
- cattle (and beef-derived products)
Any company placing these goods on the EU market or exporting them from the EU will be required to prove that they do not originate from land subject to deforestation or forest degradation.
More practical information about the EUDR Regulation – including company obligations, penalties, risk classification system, compliance preparations and ESG links – is available in our previous article: EUDR Regulation – new obligations for companies in Poland from 30 December 2025.
Another deferral of the EUDR Regulation – what did the EU institutions decide?
During trilogue negotiations between the European Council, the European Commission and the European Parliament, a one-year extension of the application deadline was proposed. In December 2025, the European Parliament voted in favour of this proposal.
According to the adopted changes:
- large and medium-sized enterprises must comply with the EUDR Regulation from 30 December 2026
- micro and small enterprises – from 30 June 2027
Experts emphasise that, despite differences in position, all EU institutions agree on one point: the regulation is necessary, and forest protection is a shared goal of the European Union.
Why has the EUDR Regulation been postponed?
A key argument for the deferral was concern over the technical and organisational readiness of both EU Member States and businesses. In particular, the following issues were highlighted:
- risk of insufficient capacity of the TRACES NT IT system, which is intended to process due diligence statements
- uneven levels of company preparedness across EU Member States
- challenges faced by micro, small and medium-sized enterprises in building due diligence systems across supply chains
However, experts also note that while the deferral is beneficial in the short term, it may undermine legal predictability and delay the regulation’s actual environmental impact.
Business obligations under the EUDR Regulation
The EUDR Regulation introduces extensive due diligence obligations. Companies will be required to:
- identify the origin of raw materials down to the specific plot of production
- assess the risk of deforestation throughout their supply chains
- collect and archive documentation confirming compliance with the EUDR
- submit due diligence statements before placing products on the EU market
Non-compliance may result in heavy financial penalties, confiscation of goods, or even exclusion from the EU market.
Facilitations and simplifications under the EUDR Regulation
The amendment adopted by the European Parliament also introduces certain simplifications. The obligation to submit due diligence statements will rest with the entity that first places the goods on the EU market. Companies further along the supply chain will not be required to duplicate documentation – they will only need to pass on the reference numbers of previously submitted statements.
Additionally, a new category of small primary producers has been introduced. They will be allowed to submit a simplified, one-time declaration instead of multiple statements.
The European Commission has also announced a further review of the EUDR Regulation and possible additional simplifications by the end of April 2026.
EUDR Regulation and FSC certification
In the context of preparing for the EUDR, Forest Stewardship Council (FSC) certification plays an important role. The FSC system covers key elements required by the EUDR Regulation, such as:
- traceability of raw material origin
- deforestation risk assessment
- verification of source legality
- documentation of the entire supply chain
For many companies, FSC certification can be a valuable support in adapting to the new regulation.
The scale of the challenge – what do the figures say?
According to the FAO’s “Global Forest Resources Assessment 2025”, the world has lost 489 million hectares of forest between 1990 and 2025 – an area larger than the entire European Union. Although the pace of deforestation is slowing, it still remains alarmingly high.
In Poland, the EUDR Regulation is expected to apply to over 120,000 companies, making it one of the most significant environmental regulations impacting Polish business in the coming years.
What should companies do now?
Although the EUDR Regulation has been postponed, experts agree: preparation should not be delayed. The additional time should be used to:
- analyse supply chains
- implement due diligence procedures
- assess legal and operational risks
- prepare reporting and documentation systems
The EUDR Regulation has the potential to become a global benchmark in the fight against deforestation. For businesses, this means not only new obligations, but also an opportunity to build competitive advantage through transparency, accountability and sustainable development.
If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.
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