European Commission Proposes Further Delay to EU Deforestation Regulation (EUDR)

The European Commission has proposed a further 12-month delay to the full implementation of its flagship regulation on deforestation-free supply chains. Originally due to apply from December 2025, the rules had already been postponed once and are now expected to take effect in December 2026.

The delay is due to technical challenges in developing the central IT system that will handle large-scale compliance submissions. The platform is being designed to process complex supply chain data at scale, but has proven slower to implement than anticipated.

The Regulation on Deforestation-Free Products (EUDR) is the EU’s response to the role of global trade in driving deforestation and forest degradation. It replaces the EU Timber Regulation (EU 995/2010) and requires companies to prove that certain commodities, and products derived from them, are not linked to deforestation after 31 December 2020.

The law covers seven key commodities and many of their derivative products:

• Cattle
• Cocoa
• Coffee
• Palm oil
• Rubber
• Soy
• Timber

The rules apply both to goods placed on the EU market and to those exported from it.

Under EUDR, companies operating within the EU that handle certain deforestation-risk commodities are subject to strict due-diligence rules. The main groups affected are:

• Operators: Businesses that place relevant products on the EU market or export them, whether through selling, importing, or processing. They must prepare and submit due-diligence statements for every transaction.
• Traders: Larger businesses that trade in relevant products without necessarily processing them. These companies are also required to carry out due diligence and ensure supply-chain transparency by passing on compliance information.
• SMEs: Small and medium-sized enterprises face equivalent requirements, but can rely on reference numbers from earlier supply chain submissions if a product has already been covered.

Companies in scope must demonstrate that products are:

• Deforestation-free after 31 December 2020
• Compliant with local laws in the country of origin

To meet these obligations, operators will need to:

• Collect detailed supply chain information, including the geolocation of production land
• Assess and document risks of deforestation
• Submit due-diligence statements through the EU’s online system

Records must be kept for at least five years, with stricter checks for products from high-risk countries such as Belarus, DPRK, Myanmar and Russia.

Member States have discretion over penalties, but measures include:

• Fines of at least 4% of annual EU turnover.
• Seizure or confiscation of goods.
• Exclusion from public procurement processes.

The EUDR formally entered into force on 29 June 2023, but the Commission has requested an extension to the application dates:

• 30 December 2026 – Rules apply to medium and large operators and traders.
• 30 June 2027 – Rules apply to micro and small enterprises.

Deforestation is a major driver of climate change and biodiversity loss. The EU estimates that the EUDR could reduce carbon emissions linked to EU consumption by 32 million tonnes per year and protect some of the world’s most vulnerable ecosystems.

By requiring supply chain due diligence, the regulation aims to shift global trade toward more sustainable practices.

Although not part of packaging compliance, the EUDR reflects a broader trend in sustainability regulation. Companies in food, agriculture, and timber with international supply chains will need to engage closely with their suppliers to ensure compliance. Emerging technologies such as satellite monitoring and blockchain traceability are already being deployed to meet these demands, while industry groups are calling for clarity and consistent data standards.

The EUDR is entirely separate from UK packaging Extended Producer Responsibility (EPR).

• Packaging EPR: Focuses on producers financing and reporting packaging placed on the UK market.
• EUDR: Focuses on the origin of raw materials (e.g. timber, soy, palm oil, cocoa, coffee, rubber, and cattle) and whether they are linked to deforestation.

This means that if your business simply places products into packaging in the UK and exports them to the EU, the EUDR does not apply. The regulation only applies to companies that import or export the listed raw commodities themselves. Packaging made from these materials is not in scope unless you are directly responsible for placing the raw commodity onto the EU market.

In short: EUDR and packaging EPR are separate regimes, and most UK producers only need to consider packaging EPR.

If you need help in meeting your packaging compliance obligations, our experts are here to provide clear guidance and practical solutions. Contact our team today for tailored compliance support and straightforward, reliable  advice.