Second delay of the EU Deforestation Regulation under consideration

On 23 September 2025, the European Commission issued a letter to inform about the intention to propose a possible further delay of the EU Deforestation Regulation (EUDR). Currently, the Regulation’s application date is 30 December 2025. The application date was already postponed once, from 2024 to 2025. With this letter, the Commission advances the possibility to postpone it by 30 December 2026.

Why another delay of the application date

Article 33 of the EUDR sets the provisions for the development of an IT system for economic operators to submit their due diligence statements. In the letter published at the end of September, the Commission explains that this system is not ready to sustain the large number of expected operations. Thus, the Commission is considering the possibility to propose a further delay by another year.

In this context, several environmental organisations and some major companies from the chocolate sector express their concerns over the Commission’s announcement. In particular, in a joint letter from 2 October 2025 different organisations and companies point out that they have been actively preparing and investing in compliance with the EU Deforestation Regulation and propose some pragmatic solutions to the Commission to avoid a further delay.

EU Deforestation Regulation sets provisions on cosmetic raw materials

With the goal to address deforestation and forest fragmentation, the new EU framework requires operators and traders to collect geographic coordinates of land plots where their commodities are produced. Traceability has to demonstrate that there is no deforestation occurring in the lands where the products come from. This list of raw materials concerned includes cattle, cocoa, coffee, oil palm, rubber, soya, and woods, and some of their derivates as well.

Whether the EUDR applies to brand-owners’ raw materials depends on the dynamics of their supply chain, where their suppliers are based, and on their imports and exports.

For a case-by-base assessment, contact COSlaw Team here or at coslaw@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.