EUDR deadlines: every date that matters

In short

• The next binding date is 30 December 2026. Two earlier application dates have already come and gone without ever biting.
• 30 June 2027 is a narrow deferral, not a general small-company exemption, and it excludes former timber regulation products.
• The Commission's simplification review landed on 4 May 2026 and did not move the dates, so there is no third delay to wait for.

The next date that binds anyone is 30 December 2026, when the prohibition and the due diligence obligations start applying. A narrow group gets until 30 June 2027. If your notes say 30 December 2025, or 30 December 2024, both of those are superseded application dates that were amended away before they ever took effect, which is why so much published guidance disagrees with itself. There is no third postponement in prospect: the Commission reviewed the file in May 2026 and left the dates alone.

Which dates are already spent, and which are still ahead?

Why does everything you read give a different date?

Because the application date has been amended twice, both times on 19 December, shortly before it would have applied.

Article 38(2) originally read 30 December 2024. Regulation (EU) 2024/3234 of 19 December 2024 replaced it with 30 December 2025. Regulation (EU) 2025/2650 of 19 December 2025 replaced Article 38 in full and set 30 December 2026. Anything written before late December 2025 is therefore describing a date that no longer exists, and the volume of that material is enormous relative to the volume written since.

The failure mode this creates is not simply lateness. It is a planning error in the other direction: a company that has been told the rule started on 30 December 2025 and has heard nothing since often concludes that either it is already non-compliant or that the whole thing evaporated. Neither is true. The obligations have not yet applied to anybody.

Is a third delay coming?

The honest answer is that nothing suggests one, and the reason is documented.

Regulation (EU) 2025/2650 inserted a new Article 32(1a) requiring the Commission to produce a simplification review by 30 April 2026. The report landed on 4 May 2026 as COM(2026) 191 final. It did not reopen the regulation and it did not move the application dates. That is the closest thing to a formal answer the file has produced, and it points the other way.

Planning on a delay that has been declined is an expensive way to be wrong, because the work that 30 December 2026 requires of an operator is field-level traceability, and that is a supplier programme with a lead time measured in seasons rather than weeks.

Who exactly gets until 30 June 2027?

A much narrower group than "small companies", and the two conditions attached to it are the part that gets lost.

The deferral covers operators who are natural persons or micro or small undertakings within the meaning of Article 3(1) or 3(2) of Directive 2013/34/EU. First condition: the undertaking must have been established as micro or small by 31 December 2024. A business that met the size test later does not qualify. Second condition, and the one that catches timber merchants: the deferral does not apply to products covered by the Annex to Regulation (EU) No 995/2010. For those products, micro and small operators start on 30 December 2026 like everyone else.

Note also who the deferral does not mention. It is written for operators. Downstream operators and traders sit under a different and much lighter set of obligations, and the interesting question for most EU manufacturers is which of those two categories they fall into rather than which date they get.

What is the date in your own calendar?

Not 30 December 2026. It is whatever date your suppliers have to deliver plot-level information by, working backwards from it.

An operator's due diligence statement rests on geolocation of the plots of land where the commodity was produced and evidence that production complied with the law of the country of production. Neither of those is something you generate internally on the day. They come from counterparties, often several tiers away, sometimes in a different growing season from the one you are buying in. If the first request goes out in December 2026, the file will not be ready.

For a downstream operator the internal date is different and smaller: the point at which your goods-in process can reliably capture and retain the due diligence statement reference numbers or declaration identifiers from the party upstream. That is a purchase-order and ERP question, and it is worth answering before your supplier starts sending the numbers rather than after.

Which dates on this page should you not plan around?

One, and it is worth naming because it is circulating.

A Commission delegated regulation amending the Annex I product list was adopted on 13 July 2026. It would remove cattle hides, skins and leather and retreaded tyres, and add soluble coffee, frozen cattle tongues and a list of palm oil derivatives. Under Article 35(6) it enters into force only if neither Parliament nor Council objects within two months of notification, extendable by a further two months. It was transmitted to the Council on 14 July 2026 and the scrutiny period had not expired on 28 August 2026. Until it appears in the Official Journal, it is not law, and no plan should assume either that leather is out or that soluble coffee is in.

Where does the carbon calendar meet this one?

Only in the sense that the same people are doing both jobs with the same purchase data.

EUDR itself has no carbon deliverable. It asks for geolocation, legality, a documented risk assessment and a statement, and it never asks for an emissions figure. If a carbon reporting deadline is competing for the same team in the same quarter, the sequencing point is that origin-level traceability collected for a deforestation file also improves the emission factors you can defend for those ingredients afterwards. Doing the traceability first and the footprint second is usually cheaper than the reverse.

If it is the emissions half of that calendar that is slipping, carbon footprint consulting is the relevant service, and a first inventory can be built on the Hedgehog platform, which reports 5,000+ users. The honest constraint on any timeline built around it: a small business reviewer on G2 in August 2026 said that once the data is loaded it works well, and that loading it is the challenging part. If you are counting weeks, count that one properly. For the customer-questionnaire side of the same quarter, the value chain cap on ESG questions sets out what you can decline.

Sources: Regulation (EU) 2023/1115, Regulation (EU) 2024/3234 and Regulation (EU) 2025/2650 as published in the Official Journal, the European Commission EUDR page, COM(2026) 191 final of 4 May 2026, and Council document ST-11910-2026-INIT. Hedgehog facts from the Hedgehog platform and Hedgehog on G2. Verified 28 August 2026.

Facts on this page were last verified on 2026-09-17.