EU Deforestation Regulation (EUDR) 2026 Update

A phot of Noah Taetle, Assent regulatory compliance expert and sustainability specialist.
By Noah Taetle

Featuring insights from guest author Jinal Surti, CEO of Epoch

The EU Deforestation Regulation (EUDR) has been delayed to December 30, 2026. As part of the sweeping Omnibus Simplification Package, the EUDR was initially delayed from 2024 to December 30, 2025. Now it’s been pushed back another year, and will be reviewed again in April 2026 with the possibility for further simplification. 

But this doesn’t mean manufacturers can put their EUDR compliance preparation on hold. This brief pause gives you more time to collect data from your suppliers — and it means there’s less excuse for missing data or errors come deadline. The regulatory delays give companies with complex supply chains precious time to refine their scope, upskill their suppliers, absorb more guidance from competent authorities, and make sure they are compliant with requirements. Proactive companies can even turn regulatory delays into a competitive advantage

Assent has teamed up with Jinal Surti, CEO of our EUDR partner Epoch, to answer some of the biggest questions manufacturers have about the recent EUDR update. 

Summary: EU Deforestation Regulation Update

The EUDR’s application is postponed to December 30, 2026 (June 2027 for small and micro operators), with an April 2026 review, but core due diligence and traceability obligations remain intact. Amendments introduce a “downstream operator” category, TRACES registration and data collection duties for first-tier actors, and a simplified declaration option for micro/small primary operators. Manufacturers should use the extra time to train suppliers, close data gaps, assess deforestation risk to plot level, and implement tools and processes for defensible DDS submissions. Proactive programs can create competitive advantage through supply chain risk mitigation, optimized sourcing, access to sustainable finance, and streamlined reporting while avoiding penalties and market exclusion.

What Does the EUDR Amendment Include?

  • The application of the EUDR is postponed for large and medium operators until December 30, 2026, with small and micro operators given until June 2027.
  • A new category, “downstream operator,” was introduced with the same regulatory obligations as a trader.
  • The first tier of downstream operators and traders are required to register in the TRACES system and should collect due diligence statement reference numbers and small or micro identification numbers.
  • A new category for “micro or small primary operators,” in the EU or low-risk countries that place relevant products on the market or export those products which they themselves produce in that country. Companies in this category do not have to submit a due diligence statement (DDS).
  • Micro or small primary operations must now submit a one-time simplified declaration in the information system and receive a declaration identifier. 
  • The EU Commission will issue a simplification report by April 30, 2026, reviewing the regulatory burden on operators.
  • In Annex I, in the table, the line ”‘ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans of paper” is deleted.

What the EU Deforestation Regulation Updates Means for Companies

The biggest struggle we’ve seen manufacturers face is training their suppliers on the requirements of the EUDR, because the regulation is  unlike traditional supply chain frameworks. 

For example, finding the exact parcel of land the EUDR commodity was sourced from and proving it was not previously forested as late as 2020 is a large ask. Especially for suppliers at varying levels of sustainability buy-in, who may not have their own responsible sourcing programs to provide this type of data. 

That’s why having an extra year to collect preliminary data and discover where deforestation risks are highest in the supply chain is vital to preparing for compliance at the end of 2026. Right now, you should be:

  • Educating suppliers on deforestation due diligence and helping them scope which materials fall under EUDR.
  • Preparing surveys and reaching out to suppliers.
  • Conducting gap analysis on missing data. 
  • Identifying top deforestation risks in your supply chain.
  • Evaluating EUDR compliance software and product sustainability platforms.

What Are the Benefits of Proactive EUDR Due Diligence?

EUDR is a big undertaking, but tracing supply chains all the way back to plots of land and performing deforestation checks can generate immense value. When you have a foundational layer of raw material supply chain data, you tap into risk management insights that far exceed the cost of your EUDR compliance program.

Supply Chain Risk Mitigation

With a structured EUDR risk assessment process, companies can identify deforestation risks at the plot level and document mitigation steps before submitting a DDS. But getting plot-level visibility also enables supplier risk management for more than just deforestation. You can get data on water stress, for example, or overlay weather and climate data to get advance warning of events  that might disrupt a corporate supply chain. In the past years, rubber, coffee and cocoa supply chains have faced significant supply shocks that can be visible well in advance if you have a program to monitor the data. 

This data can also help identify adverse environmental impacts in the supply chain so you can get ahead of possible reputational damage or litigation. Insurance providers have even been known to lower their risk premiums for corporations that take this proactive approach to supply chain risk management. 

Optimized Sourcing

Plot-level visibility also means you can get an enhanced view of your suppliers, including production methods, volumes, and changes that may have happened over the year. Having these insights can help you evaluate supplier risks globally without the need for self-reported questionnaires. With Assent’s supplier risk management software that shows supplier risk scores in a centralized dashboard and suggests corrective actions, you can optimize and diversify your supply chain to avoid disruptions or liability risks. 

Sustainable Finance

Sustainable finance represents well over $1.85 trillion in annual bond and loan issuance. It ties discounted loans to quantifiable sustainability outcomes for corporations that can readily produce data on the environmental impact of their supply chains. 

EUDR is a key sustainability regulation, and maintaining defensible EUDR compliance may become a critical factor in securing preferential financing.  

Streamlined Due Diligence Reporting

With plot-level information, companies are also much better prepared for broader supply chain sustainability management requirements like the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CS3D), and LkSG. Companies with supply chain sustainability data can also help their customers meet their European Sustainability Reporting Standards (ESRS) requirements. Voluntary reporting becomes more streamlined when using data produced at the plot level.

Next Steps for EU Deforestation Regulation Compliance

Companies that use EUDR to establish a supply chain visibility and optimization platform will benefit significantly as they look beyond EUDR and leverage that data for risk mitigation and productivity gains. If you’re proactive about it, the overall value created will pay for the cost of implementing an EUDR program multiple times over. But you need to begin now, while you still have time to engage suppliers, identify compliance gaps, and analyze supply chain data. 

To learn how to get started, download Assent’s Product Sustainability Handbook or book a demo of our EUDR compliance software

FAQ: 2025 EU Deforestation Regulation (EUDR) Update

Here’s what you need to know about the delay to EUDR requirements according to the changes published in December 2025.

What changed in the 2026 EU Deforestation Regulation (EUDR) update?

The EU Council adopted revisions that postpone the application of the EU Deforestation Regulation (EUDR) while introducing simplification measures. Large and medium operators must comply by December 30, 2026, and small and micro operators have until June 2027. A new category of “downstream operator” was introduced, and certain small or micro primary operators may submit a simplified declaration instead of a full due diligence statement (DDS). These changes provide additional preparation time but do not reduce the regulation’s core due diligence and traceability requirements.

What are companies required to do under EUDR by 2026?

Companies placing in-scope products on the EU market must demonstrate that their goods are deforestation-free as of December 31, 2020; produced in accordance with the relevant legislation of the country of production; and covered by a DDS. This requires tracing commodities to the exact geolocation of the plot of land, conducting a risk assessment, mitigating identified deforestation risks, and maintaining auditable supply chain documentation. Commodities in scope include cattle, cocoa, coffee, palm oil, rubber, soya, and wood, along with many derived products.

 

What are the risks of non-compliance with EUDR?

Non-compliance penalties are determined by EU member states and may include fines of up to 4% of total annual EU turnover, confiscation of goods or revenues, temporary exclusion from public procurement, and public naming of non-compliant companies. Beyond financial penalties, the most immediate risk is loss of EU market access. Without a valid Due Diligence Statement, in-scope products cannot legally be placed on the EU market.

How should companies use the 2026 delay strategically?

The postponement to 2026 should be viewed as a strategic preparation window, not a pause. Companies should use this time to improve supplier engagement, close data gaps in traceability, implement structured risk assessment processes, centralize supply chain data management, and evaluate EUDR compliance software. Building traceability and defensible due diligence processes now will also strengthen readiness for related EU sustainability requirements.

A phot of Noah Taetle, Assent regulatory compliance expert and sustainability specialist.
Noah Taetle
Sustainability Specialist

Noah focuses on ESG, sustainability, and due diligence issues. His work centers on Enhanced Supplier Screening. He studied sustainability at Arizona State University, with a focus on energy and policy,  Read More

A phot of Noah Taetle, Assent regulatory compliance expert and sustainability specialist.
Noah Taetle | Sustainability Specialist

Noah focuses on ESG, sustainability, and due diligence issues. His work centers on Enhanced Supplier Screening. He studied sustainability at Arizona State University, with a focus on energy and policy, and he graduated from Barrett the Honors College at ASU. ...

Read More

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