Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
Update, 4 November 2026: this article describes the situation at the time of publication. Under Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, 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 and do not submit due diligence statements. For the current state, read What actually happens on 30 December 2026.
Momentum around the proposed delay of the EU Deforestation Regulation (EUDR) continues to shift as both industry and policymakers react to the growing uncertainty over the enforcement timeline.
Since the European Commission announced its plan to propose a one-year delay to enforcement, pressure from multiple sides has intensified, and the EUDR industry pushback against a second delay is now public. The European Parliament’s October plenary agenda (6–9 October) does not include EUDR, meaning there will be no discussion or vote this month. This narrows the window for the Commission, Parliament, and Council to reach a final decision, which now appears most likely in December, very close to the current enforcement date of 30 December 2025.
EUDR industry pushback intensifies
Recent weeks have seen a coordinated EUDR industry pushback from some of the largest agri-food and consumer goods companies, including Nestlé, Ferrero, Mars, and Olam Agri. In a joint letter to EU officials, these companies warned that another delay could undermine confidence in EU climate and forest goals and erode trust in the consistency of environmental policy.
They also expressed concern that postponement would penalize companies that have already invested heavily in compliance systems, traceability technology, and supplier engagement. Many have called for the Commission to address technical challenges without resetting the entire timeline.
Environmental groups, including the Rainforest Alliance, have also criticized the proposed delay, urging the EU to maintain pressure while offering stronger technical and financial support to smallholder producers in affected regions.
Meanwhile, other industry groups have pushed for grace periods or force majeure provisions, suggesting that companies should not be penalized if IT system limitations make timely DDS submission impossible.
Economic implications of the EUDR industry pushback for EU and global trade
The uncertainty surrounding EUDR’s enforcement is already influencing trade dynamics, investment decisions, and market confidence.
- Trade and supply chain effects: Delays risk slowing import flows of key commodities such as cocoa, coffee, palm oil, soy, and timber as exporters hesitate to ship products without clarity on due diligence obligations. Ivory Coast, the world’s largest cocoa producer, recently reported that it had achieved traceability for only around 40 percent of its cocoa exports, a sign of how tight the transition timeline remains.
- Investment impact: Companies that have already invested in compliance infrastructure, data systems, and traceability tools may now face sunk costs if timelines shift again. Investors and compliance service providers are also reporting slower deal activity while clients await final decisions.
- Regulatory credibility: Each postponement increases the perception that enforcement can be negotiated, which risks weakening confidence in EU regulatory stability and environmental leadership. A consistent and predictable approach is essential to maintain both investor confidence and global credibility.
Wider economic ripple effects: Studies indicate that the direct macroeconomic impact of EUDR compliance on EU GDP is likely limited, but uncertainty may dampen near-term trade activity and investment in affected sectors. For exporting countries, delays may slow progress on traceability and forest monitoring systems that were designed to align with the EUDR timeline
What businesses should do now
The ongoing political uncertainty and diverging opinions make it increasingly important for businesses to remain proactive. Companies that continue preparing will be better positioned to maintain market access, avoid supply chain disruption, and demonstrate reliability to both customers and regulators.
Showing EUDR readiness is no longer just about compliance. It is becoming a measure of market credibility and leadership in sustainable sourcing.
How EUDR Passport helps businesses stay ahead
EUDR Passport offers a low-risk way to continue preparing, even while enforcement dates are being debated.
- Pay per product profile, from €90 a year with unlimited DDS and no upfront fees
- Guided workflows for every compliance step
- Supplier collaboration tools for collecting and reusing documentation efficiently
- Direct DDS filing to the EU Information System with instant confirmation
EUDR Passport gives you a flexible, affordable way to stay ready without committing unnecessary resources while the final decision is still pending.
Learn more about EUDR Passport
Related reading: what changed in the EU Deforestation Regulation since December 2025 for the current state of play, and EUDR Passport to prepare whatever the date.
Need software for EUDR due diligence? EUDR Passport is free to set up, free for your suppliers, and costs €90 per product profile per year with unlimited DDS.
30 DECEMBER 2026
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