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MILAN – The prospect of a further delay to the implementation of the EUDR regulation is emerging. The controversial Regulation(EU) 2023/1115, which entered into force on 29 June 2023, aims to prevent products associated with deforestation and forest degradation from being sold or exported within the European Union.
The EUDR applies to seven commodities: palm oil, cattle, soy, coffee, cocoa, timber, rubber, and products derived from the listed commodities (such as beef, furniture, or chocolate).
Commodities and products covered by the Regulation may not be marketed or exported in or from the EU, unless all the following conditions are fulfilled:
- they are deforestation-free;
- they have been produced in accordance with the relevant legislation of the country of production; and
- they are covered by a Due Diligence Statement (as set out in Annex II)
This new legislation was initially scheduled to become applicable on 30 December 2024. However, the EU Parliament and the Council agreed to the Commission’s proposal to delay its application by one year to give companies and authorities more time to better prepare for its implementation.
In the meantime, the EU Commission announced the launch of the EUDR Information System for users to submit and manage Due Diligence Statements.
Furthermore, on 15 April 2025, the EU announced a first package of measures to simplify the implementation of the Regulation.
The Commission is now planning to propose a second postponement. The proposal was revealed by the online newspaper Euractiv and is contained in a letter from the European Commissioner for Environment, Water Resilience and a Competitive Circular Economy, Sweden’s Jessika Roswall.
In the letter, Roswall informed the Chair of the European Parliament’s Committee on the Environment, Climate and Food Safety, Antonio Decaro, and the Danish Presidency that the Commission is considering postponing the entry into application of the EUDR for one more year.
Roswall justifies the request for a postponement by citing problems related to the IT platform, which plays a crucial role in managing and verifying the supply chain compliance for the purposes of the EUDR.
Despite the efforts to simplify the process, there is concern about the IT system, given the amount of data to be entered, the Commissioner explains in the letter.
“Over the last year, the Commission has been deploying the IT system in close contact with stakeholders,” says the letter.
“In this context, new projections on the number of expected operations and interactions between economic operators and the IT system has led to a substantial upward reassessment of the projected load on the IT system.
This is linked to a number of factors. Among these, one issue is related to the way economic operators can choose to interact with the IT system to facilitate their operations. Another is related to the obligations placed on downstream operators by the EUDR, despite efforts over the last months to provide simplification to stakeholders. Further factors relate to the high volume of small packages that are imported into the EU, or the impact on the length of replies to operators of various internal checks by the Commission or the Competent Authorities of the Member States related to submitted data.
Based on the available information, the Commission’s assessment is that this will very likely lead to the system slowing down to unacceptable levels or even to repeated and long-lasting disruptions, which would negatively impact companies and their possibilities to comply with the EUDR. Operators would be unable to register as economic operators, introduce their Due Diligence Statements, retrieve the necessary information from the IT system, or provide the necessary information for customs purposes where relevant.
This would severely impact the achievement of the objectives of EUDR, but also potentially affect trade flows in the areas covered by the legislation.”
“Despite efforts to address the issues in time for the entry into application of the EUDR, it is not possible to have sufficient guarantees that the IT system will be able to sustain the level of the expected load.
In view of this, the Commission is considering a postponement of the entry into application of the EUDR, currently foreseen for 30 December 2025, for one year, in order to avoid uncertainty for authorities and operational difficulties for stakeholders in the EU and third countries, and to allow time to remedy the identified risks.”
The EPP member leading negotiations on the file, Germany’s Christine Schneider (CDU), argued that “the renewed postponement clearly shows: the problems run deeper and cannot be solved by further transitional periods or non-binding guidelines,”
She also relaunched the idea of creating a new category called “zero risk”, which could exempt certain countries, including EU Member States.
The postponement requires the approval by the European Parliament and Member States. This is far from a simple and straightforward process, as we saw last year, when the one-year extension approved during the last parliamentary session of the year.
News from Brussels failed to appease the coffee markets, which rose sharply again on Wednesday, 24 September, recovering significantly from the previous day’s lows.
In New York, the main contract (December) gained 5%, rising to 367.75 cents. In London, the contract for November delivery increased by 2.5% to close at $3,319.
