On 23 September 2025, the European Commission issued a letter to inform about the intention to propose a further postponement of the EU Deforestation Regulation. After a first delay, the Regulation on deforestation-free products (EUDR) was scheduled to apply from 30 December 2025. With this announcement, the Regulation could be subject to a second delay of one year, with the application date postponed to 30 December 2026.
IT system for products transactions not ready
As required by the EU Deforestation Regulation (Article 33), the Commission has been developing an IT system for economic operators to submit their due diligence statements. In the letter, the Commission argues that this system is not ready to sustain the large number of expected operations. While aiming at improving the IT system architecture and performance, the Commission cannot guarantee that it will be ready to sustain the expected load by the current application date.
Organisations and businesses express their disappointment
On 7 October 2025, the WWF issued a joint letter on this additional delay. Together with the WWF European Policy Office, the signatories include ClientEarth, Environmental Investigation Agency, Fern, Forest Peoples Programme, Global Witness, and Greenpeace European Unit. The associations express their astonishment and disappointment towards the missed goal of developing this system by the second postponed application date.
Delays have a direct impact on the climate and the environment as well as on the rights of indigenous and communities depending on forests. In addition, a proposal to delay also undermines the credibility of the EU regulatory system and its capabilities to foster innovation and competitiveness as many businesses have already been working on the implementation of the Regulation. Indeed, on 2 October 2025 different organisations and companies jointly published a letter expressing their concerns about the delay. The signatories point out that they have been actively preparing and investing in compliance with the EU Deforestation Regulation and are on track to comply with the current deadline. Interestingly, this letter proposes some pragmatic solutions to the Commission to avoid a further delay. These include:
- Considering the unavailability to use the IT system as “force majeure” for compliance.
- A grace period during which the fines will be suspended and controls reviewed in light of non-compliance with the IT system registration provisions.
- Establishment of a technical committee to oversee the implementation and facilitate technical discussions between authorities and operators.
Among the almost 30 signatories of this letter, there are different organisations such as Alliance for the Preservation of Forests, Fair Trade Advocacy Office, International Tropical Timber Technical Association, VOCAL Coffee Alliance, Rainforest Alliance as well as major chocolate companies such as Ferrero, Nestlé, Tony’s Chocolonely, and Mars Wrigle, among others.
How the EU Deforestation Regulation applies to businesses
Whether you are based in the EU or outside, the EU Deforestation Regulation can apply to you. To assess whether your business must comply with this Regulation, contact us here or at prodlaw@obelis.net.
References:
European Commission (2025). 23 September 2025. Letter to Mr. Decaro. Retrieved on 08/10/2025.
EURACTIV (2025). 6 October 2025 – The European Union Regulation on deforestation-free products (EUDR). Retrieved on 08/10/2025.
Business & Human Rights Resource (2025). 2 October 2025. The European Union Regulation on deforestation-free products (EUDR). Retrieved on 08/10/2025.
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