Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
Let us be honest about the elephant in the room. The EU has now postponed the EUDR twice, both times late in the process, after companies had already spent money and effort preparing. Operators must comply from 30 December 2026. Micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. Downstream operators and traders of any size must comply from 30 December 2026. After two delays, it is genuinely hard to summon the motivation to start early on something the EU keeps moving.
That frustration is legitimate, and if you want to channel it, channel it at the lawmakers. Tell them that moving the goalposts twice, at the last minute, damages the very businesses trying to comply. It is a fair complaint and worth making.
But here is the uncomfortable operational truth: protesting does not move your supply chain, and waiting to see whether Brussels changes its mind again in November or early December is not a plan. It is a gamble, and the downside lands entirely on you.
The work is upstream, and it is slow
Collecting geolocation data for every plot, legality documentation, and supply-chain mapping is not a same-week exercise. For commodities sourced through cooperatives and smallholders, a single product can sit on top of hundreds of plots, and the data often does not exist in a usable form until someone goes and gets it. Realistically, getting a supply chain to respond, gather, and return compliant information can take months, not days.
And that is the easier case. If your products do not qualify for the simplified due diligence procedure, the burden goes up, not down. You move into full due diligence: a complete risk assessment, and where risk is not negligible, the collection of additional documentation from suppliers to bring it down. More questions, more documents, more back-and-forth, and more time. The suppliers least able to respond quickly are frequently the ones you most need data from.
These lead times are the whole point. You cannot compress three months of supplier engagement into the final fortnight of December.
We have seen this film before
EUDR raises the stakes further, because every shipment must be covered by a due diligence statement and the test is binary. One DDS can cover several shipments of the declared quantity placed within one year of submission, provided due diligence covers the whole quantity. Without a valid reference number in your customs declaration, your goods are not released for free circulation. No reference number, no entry. And that reference number only exists once you have submitted a Due Diligence Statement, which in turn requires that you have already done the due diligence and can stand behind a negligible-risk conclusion. The data has to exist before the goods arrive, not after.
So the failure mode is not a fine you can absorb as a cost of doing business. It is product stuck at the border, supply interrupted, customers unserved. For a business that imports continuously, that is not an administrative hiccup. It is an operational stop.
What should you do before the EUDR deadline?
- Map your products and supply chains. Work out how many distinct products (commodity, plots, supplier, country, role) you actually have in scope. That number drives everything.
- Start the supplier outreach early. This is the long pole. The sooner suppliers are engaged and uploading, the less it hurts later.
- Identify your harder cases now. Flag the products that will not qualify for simplified due diligence, because those need the most lead time and the most documentation.
- Build the profiles, even before the deadline is certain. Preparing your data is useful regardless of exactly when the obligation bites, and it costs you nothing to have it ready early.
None of this is wasted effort if the date moves again. A mapped supply chain and a set of ready, monitored product profiles are an asset whenever the regulation lands. What is wasted is the panic of trying to assemble all of it in the last few weeks, against suppliers who are not ready, with goods waiting at the border.
The EU may yet surprise everyone again. Your suppliers will not move any faster because of it. Start now.
Trusty’s EUDR Passport supports and guides your risk assessment and due diligence end to end, from supplier outreach to submission. The final assessment and compliance decisions remain yours. We make getting there faster, clearer and audit-ready.
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Frequently asked questions
Operators must comply from 30 December 2026. Micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. Downstream operators and traders of any size must comply from 30 December 2026.
The slow work is upstream: collecting geolocation data for every plot, legality documentation and supply chain mapping from suppliers and often their suppliers. A single product can sit on top of hundreds of plots, and products outside the simplified procedure need a full risk assessment and additional documentation.
Without a valid reference number in the customs declaration, the goods are not released for free circulation. The reference number only exists once a due diligence statement has been submitted, so the data has to exist before the goods arrive.
Map products and supply chains, start supplier outreach early, identify the products that will not qualify for simplified due diligence, and build the product profiles now. None of it is wasted if the date moves again.
30 DECEMBER 2026
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