Policy Notice | EU Reaches Political Agreement on EUDR: Full Delay, Simplification, and a Major Review in 2026
Late on December 4th (Brussels time), the Council of the European Union and the European Parliament announced a provisional political agreement on the revised EU Deforestation-Free Regulation (EUDR).
This update does more than shift timelines—it reshapes the regulatory landscape and signals a more pragmatic approach to achieving the EU’s “zero-deforestation” ambition.
Below is a clear breakdown of what changed, what it means, and what companies should do next.
A Clear Outcome: Full Delay, Simplification, and a 2026 Re-Assessment
1. A Full Delay: All Companies Receive an Additional 12–18 Months
Large and medium-sized companies: now required to comply starting December 30, 2026
Micro and small enterprises: compliance deferred until June 30, 2027
In other words:
All exporters to the EU have gained an extra 12 to 18 months of preparation time.
This is the first major timeline shift since the regulation was adopted—reflecting an attempt to balance regulatory ambition with operational feasibility.
2. Major Simplification: Responsibilities Reallocated, Data Requirements Reduced
The agreement introduces a notable administrative relief across the supply chain.
✔ Only the “first importer” (Operator) must submit the DDS
Downstream traders will keep the DDS number only, without repeated reporting obligations.
This significantly reduces the compliance burden on intermediaries and trading companies.
✔ Micro and small “primary producers” within the EU may file a one-time simplified declaration
Once submitted, the same declaration number can be used long-term.
(This exemption applies only to EU-based small producers and has raised concerns regarding potential WTO non-discrimination issues.)
3. Exemptions Expanded: Books, Newspapers, and Printed Images Removed from Scope
Products considered low-risk for deforestation—such as printed materials—are no longer regulated under EUDR.
4. A Critical New Element: The April 2026 “Big Review”
The European Commission is required to deliver a comprehensive review by April 30, 2026, assessing:
Administrative complexity
Whether further simplification is needed
Whether entirely new legislative proposals should be considered
In practice, this means:
In 2026, the EU may discuss another delay, further simplifications, or even a partial rewrite of EUDR.
This creates a two-year window of regulatory uncertainty—and opportunity
What Does This Mean for Asian Supply Chains?
Although the timeline has shifted, the direction remains unchanged.
The EU is not abandoning its deforestation-free goal—it is simply searching for a more realistic implementation path.
For Asian manufacturers and suppliers, this change carries three implications:
1. The delay is a grace period, not a relaxation of standards
The fundamental requirement for traceable, verifiable supply chains remains intact.
2. Brands and retailers continue moving ahead regardless of EUDR’s delay
Across Europe and beyond:
Multinational brands are conducting deeper supply-chain mappin
Retailers are drafting their own EUDR-aligned requirements
Financial institutions are integrating deforestation risks into due diligence
Regulatory timelines may slow, but commercial expectations do not.
3. Early movers gain a long-term competitive advantage
A critical question for all exporters is:
Can companies build a “minimally disruptive, low-cost DDS system” that the EU would accept?
Yes—very much so.
And those who start early will benefit first.
Why Companies Should Prepare Now Instead of Waiting for 2026
Despite the delay, several facts remain unchanged:
✔ The EU’s zero-deforestation strategy is still firmly in place
Only its implementation timeline has shifted.
✔ Early compliance is always cheaper
Last-minute implementation always results in the highest cost and lowest efficiency.
✔ EUDR-style rules will soon expand to other markets
The UK, US, and Japan are drafting similar regulations.
Preparing now creates multi-market compliance with one system.
✔ Building traceability and digital evidence systems creates structural advantages
If a company builds its transparency framework in 2025–2026, it gains:
Greater bargaining power
Easier market access
More stable customer relationships
Lower supply-chain risk
Faster adaptation to future regulatory expansions
This is not a one-off cost—it is a long-term competitive moat.
Conclusion: Delay Is a Window of Opportunity, Not a Signal to Slow Down
The EUDR delay and simplification package gives Asian supply chains something rare:
a one- to two-year window to upgrade systems at the lowest possible cost.
The key is to use this period wisely:
Don’t let the delay create complacency
Start building basic traceability now
Turn compliance into a strategic advantage rather than a reactive burden
In the end, the companies that view EUDR as a catalyst—not a constraint—will be the ones that lead the market once the regulation is fully enforced.
