The EU Deforestation Regulation (EUDR) Delayed: A Necessary Pause? 

The EU Commission recently announced plans to delay the implementation of the EU Deforestation Regulation (EUDR) by 12 months. Initially set to come into force at the end of 2024 for large companies, the new deadlines of December 2025 (for large enterprises) and June 2026 (for small and micro businesses) provide additional time for businesses to align with the regulation’s stringent requirements. 

While this delay acknowledges the challenges many sectors face—especially in complying with traceability and due diligence—it also raises critical questions. The first: is this delay necessary?  

Back in July, various bodies in the timber industry signed a letter to Ursula von der Leyen, asking for a delay of the entry into application of the EUDR. This included the European Timber Trade Federation and the European Organisation of the Sawmill Industry, among others. They cited the following reasons for their request: 

1. That it puts the European manufacturing sector at a disadvantage on the international stage and creates significant administrative burdens on companies 
2. That the EUDR had a “shorter timeframe than has ever been imposed on any other industrial sector affected by comparable European legislation”. 
3. That the short length of the transition period was not reasonable to achieve the objectives set out. 
4. That an absence of country benchmarking meant the foundational idea behind the EUDR benchmarking rules, namely reducing the regulatory burden on operators and traders, would not happen. 

At the same time, they emphasised their support for the aims of the EUDR, from both an environmental and economic point of view.

Similarly, smallholder farmer representatives (Solidaridad) have called for better partnerships with producing countries and for clearer guidance, but also: 

“for the Member States and European Parliament to act decisively: extend the phase-in, but do not reopen the EUDR for discussion… avoid arresting the momentum for change the EUDR is already inspiring.” 

Certainly, there has been significant pushback against the delay on this basis, and with good reason. The second critical question is then this: can we balance the urgency of combating global deforestation with the need for smoother regulatory transitions? 

The World Resources Institute, for example, has laid out concerns that the delay could send the “wrong signal”, that “the creation of a deforestation-free commodity market can wait.” Writing in The Grocer, Leo Bottrill, CEO and founder of MapHubs, notes: 

“We are already seeing palm laggards go from seeking our help to postponing plans indefinitely. They now think the EUDR won’t happen, so will continue exporting their commodities without monitoring them.” 

The delay could tangibly damage efforts to combat deforestation and implement sustainable practices. As the collected timber industry organisations noted in their letter, that this is not just an environmental concern, but also an economic one. Illegal logging drives down timber prices, resulting in unfair competition for those operating in good faith. As above, the balance between the urgency of combatting deforestation and smooth regulatory transition is only kept here if the momentum created by the EUDR to date is maintained – rather than halted. 

The third question is this: can the European Commission learn from and build on this setback? With legislation like the CS3D coming down the pipeline, it’s important that this delay does not become a pattern for human rights and environmental legislation.  

We welcome the EU’s efforts to address stakeholder concerns and provide clearer guidance on key compliance areas. However, the core objectives of the EUDR must remain uncompromised. With additional time to prepare, we encourage businesses to stay proactive and use this opportunity to strengthen their supply chain due diligence, ensuring readiness well before the new deadlines.  

How can Ardea help?

We understand that businesses must ensure that they establish proper due diligence procedures. We support our clients by helping them identify how to manage impacts and risks, ensuring they meet legal compliance obligations and integrate best practices into their policies, procedures, and company culture. We do this through robust engagement with stakeholders, which provides a good foundation for sustainable and resilient business practice.

To find out more about how we can support you, get in touch with us at: hello@ardeainternational.com

Or for support on integrating modern slavery risk into your procurement process, consider joining our workshop on the 20th November. https://www.ardeainternational.com/education/sustainable-procurement-integrating-modern-slavery-risk/