The European Union Deforestation Regulation (EUDR) is a major piece of pending supply chain legislation. It attempts to ban the sale of certain goods in the EU that contribute to deforestation. The law is set to come into force on December 30, 2025. However, the future of the law was in limbo as at least three proposals attempt to delay its implementation:
- A request for a one-year delay based on insufficient IT infrastructure that we wrote about back in September;
- A proposed one-year delay for small and micro enterprises, put forward by the European Commission last month; and
- Most recently, the presidency attempted to negotiate a blanket one-year delay, which a recent Responsible Investor article discusses:
“The presidency’s latest proposal would see the enforcement delayed further for all firms. Larger firms would get a one-year delay to 30 December 2026, while for SMEs the rules would apply from June 2027… Other simplifications proposed by the Commission remained untouched in the Presidency’s proposal. RI understands the proposal was discussed at a member state representative meeting today, but the Presidency did not secure sufficient support for it to become the official Council mandate.”
With all of these proposals floating around, the EUDR will likely be delayed in some capacity. The question is, how those delays might affect the substance of the law. There appears to be political will to reopen the EUDR and reduce compliance obligations. We could see a pause in enforcement, accompanied by a new simplification package, which could revisit the substance of the law. One area to watch is the law’s extraterritorial scope, which could be amended under pressure from the US.
Our members can learn more about the EUDR here.
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