The European Commission is considering a postponement of the application deadline of the Regulation (EU) 2023/1115 (“EUDR”) by another year. Currently, the regulations were supposed to be applicable to the majority of entrepreneurships from 30 December 2025, and to micro and small enterprises established by 31 December 2020, from 30 June 2026. In the event of postponement, most of the regulations would only come into force on 30 December 2026.
According to information released on 23 September 2025 by Jessica Roswall, the EU Commissioner for Environment, Water Resilience and the Competitive Circular Economy, the IT system designed to handle the reporting obligations under the EUDR is not ready yet to handle the expected volume of transactions and data. In the view of the Commission, this poses a risk of overloads, disruptions and difficulties in registering obligations, which justifies the need for additional time to refine the system.
It should be emphasised that the date of application of the EUDR has not been formally postponed yet – this requires appropriate legislative action, including approval of the amendments by the European Parliament and the Council. It is unlikely that this process will encounter any major difficulties. At the same time, the introduction of additional modifications to the regulations before their application, including simplifications, may not be ruled out - as suggested by Commissioner Roswall.
What does it mean for entrepreneurs?
- more time to analyse supply chains in terms of the EUDR obligations, develop and implement due diligence procedures, and prepare IT solutions,
- due to the lack of detailed draft amendments, it is necessary to wait until the official proposals are published in order to assess whether and how they will affect preparations of entrepreneurs for the implementation of the EUDR.
Why is this important?
The EUDR does not only concern entities involved in forestry or agriculture. The new obligations will apply to all entrepreneurs participating in the production or distribution chain of products listed in appendix I to the EUDR. These are products that contain the following goods, were fed with them or were produced using them (the so-called “relevant products”): cattle; cocoa; coffee; oil palm; rubber; soybeans; wood.
In practice, this means that the regulation will cover a very broad group of entrepreneurs from various industries, including the food, automotive, retail and wholesale industries. The scope of obligations will depend not only on the role of an entrepreneur in the supply chain, but also on its size – the EU legislator provides for simplifications for entities with the status of micro, small or medium-sized enterprises.
The EU bodies will have to agree on the final wording of the act before the end of the year, before the current deadline for the EUDR obligations to come into force. Our experts are keeping a close eye on the legislative process and the positions and decisions of the EU institutions so that they can effectively support clients in preparing for the implementation of the EUDR.
Should you have any questions regarding the upcoming changes, please do not hesitate to reach out to Magdalena Standarska (magdalena.standarska@bsjp.pl) or Julia Malinowska (julia.malinowska@bsjp.pl).