Potential Delay to EU Deforestation Regulation (EUDR) Implementation: Technical Hurdles Cause Concern

By Olivia Mathai

On September 23, 2025, European Commissioner for the Environment, Jessika Roswall, announced that the European Commission is considering a one-year delay to the entry into force of the EU Deforestation Regulation (EUDR) 2023/1115. This potential postponement targets the current deadlines of December 30, 2025, for large and medium companies, and June 30, 2026, for small and micro-operators. The announcement was made during the Agriculture and Fisheries Council in Brussels, where Commissioner Roswall confirmed the move was being driven solely by technical concerns—specifically, issues with the capacity and readiness of the EUDR's Information System.

The Commission's primary concern is that the EUDR’s Information System, which serves as the central registry for Due Diligence Statements (DDS), cannot handle the anticipated volume of interactions. New projections show that the expected number of submissions would place an "excessive load" on the system, potentially leading to "unacceptable" slowdowns or even "repeated and long-lasting disruptions." Such failures would prevent companies from registering, submitting the required DDS, or accessing vital information necessary for demonstrating EUDR compliance.¹ This operational failure wouldn't just compromise the regulation's enforcement; it could also disrupt trade flows across the regulated sectors.² Commissioner Roswall explicitly stated that this proposed delay is not related to recent trade discussions with third countries but is based purely on technical concerns aimed at preventing operational failure.³

The Commissioner has so far only sent an informal letter of intent to the EU co-legislators (the Council and the European Parliament). If a formal proposal is submitted, it will reopen the legislative process, creating significant uncertainty for economic operators who are currently working to meet the original deadlines. While the focus is on a one-year delay, additional adjustments or simplifications to the regulation, such as the possible introduction of a "zero-risk" category, may also be discussed.⁴ Despite the proposed delay, no formal legislative proposal has been submitted or adopted. Therefore, companies must continue preparing for compliance with the original deadlines of December 2025 and June 2026 until a new law is formally passed.

Why the EUDR is Critical for Global Stability

The EU Deforestation Regulation is far more than a technical compliance exercise; it is a crucial global policy intervention addressing three of the planet's most severe interconnected crises: climate change, biodiversity loss, and human rights abuses. The urgency of its implementation cannot be overstated, as every month of delay translates directly into further environmental degradation.

Tropical forests are the lungs of the Earth and our most effective natural carbon sinks. Deforestation, often driven by the expansion of agricultural commodities like beef, palm oil, and soy, releases massive amounts of stored carbon into the atmosphere, directly accelerating climate change.⁵ By demanding that covered products sold in the EU are deforestation-free, the EUDR aims to reduce these emissions and help meet the EU’s climate targets under the Paris Agreement.⁶ Postponing this regulation means postponing a critical mechanism for climate mitigation.

Forests are biodiversity hotspots, housing the majority of the world's plant and animal species. Their destruction drives the global extinction crisis and undermines the health of the planet's ecological systems. The EUDR helps to safeguard critical ecological functions like water regulation, soil health, and pollination, which are essential not only for nature but also for agricultural productivity and human survival worldwide.⁷ The loss of these unique ecosystems undermines the fundamental resilience of the planet.

Deforestation is frequently linked to illegal land grabs, violence, and the violation of the rights of Indigenous Peoples and local communities, who are recognized as the most effective guardians of forest ecosystems.⁸ By including requirements for products to be legally sourced (which includes respecting land-use rights), the EUDR provides a powerful legal framework to protect vulnerable populations and ensure ethical, responsible supply chains. In essence, the proper and timely implementation of the EUDR is fundamentally about building a more stable climate, a healthier planet, and a more equitable global economy. Any delay, while technically motivated, postpones vital action on these critical, interwoven global priorities.⁹

What can you do?

Dt Master Carbon’s CCBP, enhanced with Emmy AI, enables seamless EUDR reporting compliance — all in just one click.

Dt Master Carbon's Planet Positive Platform is actively empowering companies to make significant strides in combating deforestation and improving their overall environmental impact by providing a comprehensive action-oriented ecosystem. The platform helps companies source sustainable technologies and nature-positive suppliers to adapt and mitigate their risks. Crucially, it facilitates investment in certified climate, water, and biodiversity projects—or even the development of customized insetting projects within a company's own value chain—to ensure verifiable positive contributions. Through its extensive marketplace, which features over 500 solutions, companies can find adaptation and mitigation strategies, access high-quality environmental offsets, and use the integrated MRV (Measurement, Reporting, and Verification) system, powered by satellite data and AI, to transparently track and report the genuine, measurable impact of their investments on the ground.

We encourage you to explore our CCBP here, Planet Positive Platform here. Contact us to book a demo here.

Sources:

https://www.sustainabilityinbusiness.blog/2025/09/european-commission-considers-proposal-for-a-new-one-year-delay-of-the-eu-deforestation-regulation/