On 23 September 2025, European Commissioner for the Environment, Jessika Roswall, announced that the European Commission is considering a one-year delay to the entry into application of the EU Deforestation Regulation (EUDR) 2023/1115 (EUDR), currently scheduled for 30 December 2025 for large and medium companies, and 30 June 2026 for small and micro-operators.

A formal proposal, if submitted by the Commission, would reopen the legislative process on a burning topic and would trigger, again, great amount of uncertainty for economic operators currently actively working on their compliance with obligations supposed to start at the end of this year. This may explain that, so far, only an informal letter of intent was sent by the Commission to the EU co-legislators.

Almost a year ago, the Commission similarly issued a its first proposal to delay the entry into force of the EUDR, opening the path to an expedited bur arduous legislative process.

The proposed new delay is being considered due, officially, to concerns about the IT system’s capacity and readiness.

The announcement was made during the Agriculture and Fisheries Council in Brussels at which Commissioner Roswall confirmed she would be discussing the EUDR with EU Agriculture and Fisheries Ministers. In a letter reportedly sent to both the Council and the European Parliament, the Commissioner detailed the issues with the performance of the EUDR’s Information System, particularly its ability to handle the projected volume of interactions from economic operators.

According to the new Commission’s projections, the anticipated number of operations would place an excessive load on the system potentially leading to slowdowns “to unacceptable levels or even to repeated and long-lasting disruptions”. These disruptions could prevent companies from registering as economic operators, submitting Due Diligence Statements or accessing key information, all of which are essential for demonstrating EUDR compliance. Such issues would not only compromise EUDR compliance but could also disrupt trade flows in sectors covered by the regulation.

When asked about the timing of this announcement, Commissioner Roswall emphasized that the proposed delay is not related to the recent EU trade agreement with the United States (in which the EUDR was referenced) or to discussions with third countries such as Malaysia, Japan, or the conclusion of trade negotiations with Indonesia. She clarified that the proposal is based solely on technical concerns, aimed at reducing the risk of operational failure due to current system limitations.

Next Steps

Following the letter, the Commissioner will engage with both the Council and the European Parliament to determine the next steps. While she emphasized that the Commission’s current focus is on a one-year delay, additional simplifications or adjustments to the regulation may also be discussed. Commissioner Roswall noted that it is still too early to confirm whether changes, such as the possible introduction of a “zero-risk” category, could be considered in the proposal.

Looking Ahead

While the Commission is actively considering a one-year postponement, no formal legislative proposal has been submitted. As a result, EUDR obligations are still set to apply from 30 December 2025 for large in-scope companies and 30 June 2026 for small and micro enterprises.

No formal timeline has been set, but this potential delay could mirror the initial deferral granted last year, which was fast-tracked after the Commission published its amendment proposal in October and was adopted and published in the Official Journal on 23 December 2024, just four days before the regulation was originally set to apply.

However, until a new proposal is officially tabled and adopted, companies should continue preparing for compliance as originally scheduled. Stakeholders are advised to stay informed and ready to adapt, not only to a potential change in timeline but also to possible amendments in how the EUDR will be implemented.

Background on the Information System of the EUDR

The Information System, outlined in Article 33 of the EUDR and functioning pursuant to the Commission Implementing Regulation (EU) 2024/3084, serves as a central registry for DDS submissions. It is a dedicated online tool that enables operators and traders to submit DDS electronically, demonstrating compliance with the regulation’s deforestation-free requirements. The system has been operational since 4 December 2024, and user registration opened in November 2024.

Peter Sellar contributed to this article