EU Deforestation-Free Product Law Faces Further Delays

The EU Regulation on Deforestation-Free Products (EUDR), which defines compliance obligations for businesses trading with the European market, is facing further implementation delays.

Designed to prevent the sale and export of goods linked to deforestation and forest degradation, EUDR applies to a wide range of commodities, including wood, paper, palm oil, rubber, coffee, cocoa, soy, and livestock.

On 23 September 2025, the European Commission announced it is considering another one-year delay to EUDR enforcement—postponing the application of the law from December 2025 for large companies to December 2026, and for smaller firms from June 2026 to June 2027.

This marks the second official delay as EU authorities struggle to roll out the IT infrastructure needed to handle due diligence statements and monitor supply chain transactions at scale.

Defining the EUDR

The EUDR is a core plank of the EU Green Deal, aiming to sever the link between Europe’s consumption and global forest loss. Companies placing relevant products on the EU market or exporting them from the bloc will be required to prove those goods are legal, traceable, and entirely deforestation-free.

To comply, businesses must maintain paperwork and geolocation data showing that commodities are sourced from land that has not been deforested after December 2020.

Due diligence statements will need to demonstrate negligible risk and trace every relevant batch from origin to final sale. Third-party certifications like FSC can help streamline compliance but do not serve as automatic proof; additional geolocation mapping and risk assessment remain mandatory for full EUDR compliance.

The latest delays are being linked with concerns over potential system “slowdowns” and disruptions that could stall trade and make compliance impossible for thousands of businesses.

The risk of further simplifications or legislative changes has also emerged, with some political groups pushing to amend the law’s benchmarking system and even introduce a “zero-risk” exemption for certain countries.

Implications for Metro Customers

• The delay gives economic operators slightly more time to adapt their sourcing and compliance systems but increases uncertainty for businesses who have already invested in EUDR preparation.
• Large and small companies alike must now track shifting requirements, especially as the regulation could change further in parliamentary negotiations.
• Businesses sourcing affected commodities (timber, coffee, soy, cocoa, etc.) should continue mapping supply chains, aligning procurement strategies with deforestation-free criteria, and strengthening traceability processes, particularly around geolocation data and documentation.
• If companies use FSC certification, extra steps are now needed: ensuring plot-level traceability and robust risk evaluation, not just certification documents.

What Comes Next?

The European Commission’s latest proposal is not yet final. Metro customers trading with or into the EU should stay up to date as legislative details and IT infrastructure roll out, and be ready to pivot quickly if further changes to EUDR emerge.

As enforcement eventually resumes, the EUDR is set to become a defining feature of UK–EU supply chain management and trade compliance, shaping how Metro supports customers in navigating new environmental obligations and regulatory risks.

EMAIL Andrew Smith, Managing Director, today to explore how we can support EUDR compliance and reporting.