The EUDR – Regulation (EU) 2023/1115 – has been in force since 2023, but its application has been adjusted several times. Anyone who wants to decide what to do needs a clean distinction: what is fixed, and what is the subject of ongoing political debate?
Precisely because the EUDR is so widely reported on and politically contested, plenty of half-truths circulate too. A postponed deadline is quickly reinterpreted as a "watered-down obligation", a proposal under discussion as a supposedly adopted rule. For operational planning this fuzziness is dangerous – it tempts you to wait. This article therefore sticks strictly to what is settled within the regulatory framework.
1. Postponed deadlines
The most important point first: the application deadlines have been pushed back. They apply in a staggered way according to company size.
| Large companies | from 30 December 2026 |
|---|---|
| Small & medium-sized enterprises (SMEs) | from 30 December 2026 (timber) |
| Deforestation-free cut-off date | not cleared after 31 December 2020 |
The cut-off date for deforestation-freeness has remained untouched by the postponements: 31 December 2020 remains decisive. In other words, the later application only shifts the point in time from which you must submit statements – not the substantive requirement for the goods themselves. Anyone sourcing timber from a plot that was cleared after this date has a problem even with the later deadline.
The staggering is intended above all to give smaller operations more lead time. Whether a company counts as "large" or as an SME depends on the usual EU-law thresholds for headcount, turnover and balance sheet total. When in doubt, a precise classification is worthwhile, because the deadline – and also the scope of individual reliefs – depends on it.
2. Combined statement & annual validity
One practical relief concerns the due diligence statement itself: anyone who recurrently sources similar goods from the same suppliers does not have to create a new statement from scratch for every single consignment. Instead, statements can be combined and used over a period of time, rather than being assessed separately for each shipment.
Practical benefit: Especially for operations with high delivery volumes this significantly reduces the administrative effort – while the underlying due diligence remains unaffected.
The right classification matters: a combined statement is an organisational relief, not a waiver of content. The geolocation data, the risk assessment and the legality check must still be in place per plot of production. What is dropped is the repetition of identical entries – not the substance of the check. Anyone who confuses the two risks a formally submitted but substantively incomplete statement.
3. Downstream operators no longer file a statement of their own
The most far-reaching simplification in the December 2025 amendment concerns downstream operators. Anyone who places relevant products on the market that are made from timber already covered by a due diligence statement no longer has to file a due diligence statement of their own since the change – regardless of company size. In the timber industry this typically affects sawmills processing bought-in sawn timber, joiners and large timber traders.
In place of the statement of their own comes a lighter obligation: collect the suppliers' reference numbers, pass them on and keep them for five years. Large businesses (non-SMEs) must additionally register in TRACES NT and act on substantiated indications of infringements; small businesses (SMEs) do not even have to register.
Important: The relief only applies as long as the timber used is in fact already covered. Anyone who imports themselves or sources timber from a supplier who is not yet registered remains the first-placer operator with full due diligence and a statement of their own.
4. Reliefs for SMEs
For small and medium-sized enterprises the central relief is the role as a downstream business – with the fewest obligations of all. The later deadline (30 June 2027, only for natural persons, micro and small undertakings established as such on 31 December 2024) does not help the timber sector: it only applies to products not already caught by the EUTR. An SME that resells or processes covered timber files no statement of its own, does not have to register in TRACES, and merely takes over its supplier's reference number, passes it on and documents it.
This reliance is a considerable advantage in practice: the further downstream an SME sits in the supply chain, the more likely it is that the geolocation data and risk assessments already exist – provided by an upstream operator such as an importer or forest owner. The precondition, however, is that this predecessor actually submitted its statement correctly and passed on the reference. Your own plausibility check remains advisable.
5. What is settled
- The staggered application deadlines (30 Dec 2026 / 30 Jun 2027)
- Downstream operators – even large ones – no longer file a statement of their own, but manage reference numbers
- The cut-off date of 31 December 2020 for deforestation-freeness
- The obligation to provide geolocation with a point or polygon
- Submission via TRACES NT
- The five-year retention of records
6. What is still under discussion
Beyond the settled points named here, there are ongoing political debates – for example about further simplifications for certain countries of origin or sectors. Such proposals are not automatically applicable law. Treat anything that goes beyond the confirmed rules as a matter under discussion, not an obligation. For binding information, rely on the competent authority – in Germany the BLE (Federal Office for Agriculture and Food).
Note: This article is a guide, not legal advice. The current text of the regulation is always decisive.
7. What you should do now
The postponements are no reason to wait. Building up clean supplier data and geolocation data takes time – and is necessary regardless of any future reliefs. Anyone who starts now will be prepared when the deadline arrives. You will find concrete steps in the EUDR guide and in the guide EUDR for sawmills.
Concretely this means: record and inform suppliers, collect geolocation data, clarify your own role (operator or trader) and organise the retention of records over five years. None of these steps is made redundant by the simplifications so far – they merely make the path a little more comfortable. Anyone waiting for further reliefs is only postponing the work, not the obligation.