The date is now fixed, the obligation has moved, and six product categories have left the scope entirely.
Three things happened to the EU Deforestation Regulation in 2026 that change what an importing business has to do. If you have been waiting to see whether the deadline moved again, it has not, and the Commission has now said so in writing.
This is a plain summary with sources. It is not legal advice, and where a decision turns on your specific products you should confirm it against the regulation itself.
1. There will be no third delay
On 4 May 2026 the Commission published its simplification package (COM(2026) 191 final), confirming application from 30 December 2026 for large and medium operators and stating that it will not reopen the core text of the regulation.
That matters more than another restatement of a date, because the December 2025 revision contained a review clause obliging the Commission to reassess the regulation by the end of April 2026. That review was the live mechanism through which a third postponement could have arrived. It has now been carried out, and the answer was no.
The dates, precisely:
| Who | Applies from |
|---|---|
| Large and medium operators | 30 December 2026 |
| Micro and small operators already covered by the EU Timber Regulation | 30 December 2026 |
| Other micro and small operators | 30 June 2027 |
That middle row is easy to miss. If you are a small timber business that was already inside the EUTR, you do not get the extra six months.
2. If you are not the first to place goods on the EU market, most of it no longer applies to you
This is the largest practical change and it has been under-reported.
The obligation now sits with the operator who first places a relevant product on the EU market — in most supply chains, the importer. That operator carries out due diligence, collects plot-level geolocation, assesses risk, and submits a due diligence statement to the Information System.
Everyone downstream of that point — the manufacturers, distributors and retailers who buy from them — explicitly does not need to carry out due diligence, submit due diligence statements or simplified declarations, or maintain a due diligence system.
What downstream actors must do instead:
- Keep records of their suppliers and buyers for five years
- Notify their buyers and the competent authorities if they discover a product may not comply
- Large downstream companies additionally register in the Information System, and verify that upstream due diligence was done — but only if something comes to their attention suggesting non-compliance
If you have been budgeting for a plot-level traceability programme and you are three steps down the chain, it is worth checking whether you are actually the operator the regulation is aimed at. A good many companies are not, and the Commission estimates the package reduces compliance costs by roughly 75% against the original framework.
The corollary is less comfortable for importers. The burden did not disappear, it concentrated. If you are the first placer, the obligation is now unambiguously yours, and the people below you in the chain are entitled to ask you for evidence.
3. Six product categories left the scope, three joined
On 13 July 2026 the Commission adopted a Delegated Act on product scope and an updated Implementing Act on the Information System (announcement).
Removed from scope:
- Cattle hides, skins and leather
- Re-treaded tyres
- Soybeans for sowing
- Vulcanised rubber articles
- Conveyor and transmission belts
- Aircraft and motor vehicle seats
Added, applying only from 30 December 2027:
- Soluble coffee
- Certain palm oil derivatives
- Frozen cattle tongues
If you import leather goods or rubber components, this is the paragraph that matters. Those categories are out.
The Information System reopened at the end of June 2026 after technical work, with simplified declarations for micro and small primary operators and updated API specifications.
4. What did not change
The core requirement is untouched. If you are a first placer, for every relevant product you still need:
- Geolocation of every plot of land where the commodity was produced, as coordinates rather than an address
- Evidence the land was not deforested after 31 December 2020
- Evidence of compliance with the producing country's laws
- A risk assessment, and mitigation where risk is not negligible
Country risk classification still matters, and it is worth knowing that Côte d'Ivoire and Indonesia are both classified standard risk, not low risk — so the simplified route does not apply to two of the largest cocoa and palm supply chains.
What to do between now and December
Establish whether you are the first placer. Everything else follows from this. If you are not, your obligations are record-keeping and notification, and you can stop planning for the rest.
Check your products against the revised scope. Six categories left. It takes an hour and may remove a workstream.
Find out whether you can actually get coordinates from your suppliers. This is where most programmes fail, and it is not a software problem. Smallholder supply chains often have no plot boundaries recorded anywhere, and collecting them takes a season of fieldwork, not a purchase order.
Screen what you already have. If you hold coordinates, checking them against the 2020 cutoff tells you now whether you have a problem, rather than in December. Plots that pass cleanly need no further attention; the small number that do not are where your remaining time should go.
That last point is what we built GeoTown's EUDR screening for, and it is free to use. It is a screening layer rather than a compliance certification — it tells you which plots are obviously fine, which are obviously not, and which need a closer look, and our methodology is published so you can see exactly how each verdict was reached.
The number worth remembering
Commission dry-run inspections reportedly found initial compliance among participating companies at around 40%. Twenty weeks out, with the date now fixed and no further review pending, that is the gap the industry has left to close.
Sources: COM(2026) 191 final, 4 May 2026 · Commission product scope and tools update, 13 July 2026 · Roles and responsibilities under the EUDR. This post summarises publicly available Commission material and is not legal advice.