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. One due diligence statement can cover several shipments of the declared quantity placed within one year of submission, provided due diligence covers the whole quantity.
Brussels, November 2025: The debate surrounding a potential “stop the clock” or EUDR delay to the EU Deforestation Regulation (EUDR) is less about politics and more about numbers. The scale of reporting required under the Regulation is immense, stretching from timber to soy, cocoa, and palm oil. As deadlines approach, the focus is shifting from when enforcement will begin to whether the systems and industries involved can handle the volume.
Understanding the scale
The EUDR requires every operator and trader to file a Due Diligence Statement (DDS) before placing relevant products on the EU market. Each statement must confirm that goods are deforestation-free and compliant with local laws of origin. While conceptually straightforward, the practical implementation is staggering.
Industry and Commission estimates suggest that the EU Information System will need to process more than 75 million DDS files annually across just six key commodities. The chart below highlights the approximate annual DDS volume expected per sector, based on 2025 trade data and Commission impact assessments.
Projected annual DDS volumes by commodity (2025 to 2026)
Commodity | Estimated DDS volume per year | Relative compliance burden | Primary traceability challenge |
|---|---|---|---|
Timber & wood products | 25 million | High | Fragmented smallholder data |
Palm oil | 18 million | High | Cross-border supplier chains |
Cocoa | 12 million | Medium | Plot-level geolocation accuracy |
Coffee | 9 million | Medium | Multi-origin aggregation |
Soy | 7 million | Medium | Origin verification consistency |
Rubber | 4 million | Low | Mixed-source blending |
(Sources: European Commission EUDR impact assessment; WWF EUDR Readiness Report 2025; FAOSTAT trade data; industry association forecasts.)
What the numbers mean
The combined workload of these sectors is far greater than that of previous EU product-compliance frameworks. Even with partial automation, the expected volume of DDS submissions will strain IT systems, verification workflows, and supply-chain data management.
- Timber and wood: More than 40 percent of timber entering the EU originates from smallholders or multi-tier suppliers with limited traceability data.
- Palm oil and soy: These sectors face complex cross-border supply chains where land-use verification is still inconsistent.
- Cocoa and coffee: Plot-level geolocation and farm registration remain incomplete across many producer countries.
For the European Commission and Member States, the challenge is not only managing volume but ensuring verification integrity. The EU Information System, still in phased testing, must validate and store millions of DDS records per month, each containing geographic coordinates and due-diligence documentation.
Operational readiness over regulatory delay
While industry groups have urged the EU to “stop the clock” on enforcement, policymakers increasingly frame the issue as a readiness question rather than a policy reversal. Technical bottlenecks, not political hesitation, are driving the current discussion.
The Commission’s simplification proposal of October 2025 already includes provisions to ease reporting for small operators and streamline data inputs for low-risk supply chains. However, these measures do not alter the core obligations of traceability, legality verification, and DDS submission.
Companies that interpret the debate as an excuse to wait risk falling behind. The Regulation’s scope will not shrink, and the data requirements will not disappear.
Trusty Compliance insight
Trusty Compliance built the EUDR Passport platform to support this shift. The system is designed for large-scale DDS reporting, cross-commodity data handling, and integrated filing workflows that remove friction from the compliance process. Whether enforcement begins in 2025 or moves to a later date, companies using EUDR Passport can prepare now with confidence and maintain continuity as the regulatory framework evolves.
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.
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