Summary

• Jessika Roswall, the European Commissioner for Environment, Water Resilience and a Competitive Circular Economy, has expressed concern about the Commission’s IT systems not being ready to handle EUDR reporting according to the original schedule, and the Commission is considering a possible one-year delay in applying the regulation.
• However, no official steps have been taken through formal channels, and under the current circumstances, the regulation is still set to enter into force on December 30, 2025.
• Many large corporations and authorities have announced their opposition to the proposed delay and are continuing their preparations without changes.
• For most companies, the key question is not whether EUDR will be delayed, but how their major customers intend to proceed.
• Many large corporations and retail chains are likely to enforce their own origin requirements for products by the end of 2025, regardless of whether the EUDR deadline is postponed or not.
• Halting preparations at this stage is highly risky for suppliers, and companies should continue along the planned timeline.
  
  

"For most companies, the key question is not whether EUDR will be delayed, but how their major customers intend to proceed. If the customers continue moving forward but the suppliers don't, the risk are great"

EU Deforestation Regulation (EUDR) – Status as of 06.10.2025

In the past two weeks, the media has widely discussed possible changes to the timeline of the EU Deforestation Regulation. The issue arose after a letter from Jessika Roswall (the European Commissioner for Environment, Water Resilience and a Competitive Circular Economy) to the European Parliament was leaked. In her letter, Roswall stated that the Commission’s IT system is not yet ready to process EUDR reporting. As a result, the Commission is considering the possibility of delaying application of the regulation by one year.

It is worth noting that at this stage no formal proposal to change the EUDR timeline has been made, and the matter is not included on the agenda of the European Parliament’s upcoming plenary session on October 6–9, 2025.

The EU Regulation on Deforestation-Free Products (EUDR 2023/1115) was adopted on May 31, 2023, and remains in force. According to the only decision currently in effect, the regulation will apply to large and medium-sized companies from December 30, 2025, and to micro and small enterprises from June 30, 2026.

Situation in Finland

Many domestic operators have incorporated principles of deforestation-free sourcing, transparency, and traceability into their strategies and are continuing preparations for EUDR compliance without announced timeline changes, despite news of a possible delay.

For example, the Finnish Forest Industries Federation has stated that its stance remains unchanged and preparations continue, although it also notes that the potential additional time causes uncertainty – even though many operators in the sector already have full readiness to meet the requirements (Kauppalehti, 25.09.2025).

Major players in Finland’s food and retail sectors have long been committed to deforestation-free practices and have jointly developed systems for data collection and responsibility verification, especially for high-risk raw materials. No changes have been announced to these policies following news of a possible delay. The same applies to key players in the coffee and spice industries, which emphasize long-term commitments to traceability and sustainability in their supply chains.

International Situation

Based on government websites and official statements, EU Member States are continuing EUDR implementation preparations and are still communicating the existing application dates. No public announcements of halting preparations have been made. The situation in major Member States is as follows:

• Germany: The Federal Office for Agriculture and Food (BLE) maintains its EUDR guidance and presented its planned monitoring process in week 39/2025. Official communication continues to reference the December 30, 2025, as the application date, and practical preparations are ongoing.
  
  
• France: The Ministry for Ecological Transition’s RDUE website and customs guidelines describe application and enforcement practices according to the original December 30, 2025, timeline.
  
  
• Spain: MITECO continues to state December 30, 2025, as the application date and has published descriptions of progress in national implementation.

Other International Stakeholders

• Nestlé (quoted in the media on 23.9.2025; position previously published) opposes reopening EUDR content or further delays, arguing that this would undermine the efforts of already committed supply chain partners.
  
  
• The European Tyre & Rubber Manufacturers’ Association (ETRMA) states it is concerned by the Commission’s intention to postpone the law, said Secretary General Adam McCarthy, as it risks “prolonging uncertainty for operators who have prepared in good faith and are looking forward to demonstrating their commitment.”
  
  The body also pointed out that many industry groups last year urged the Commission to carry out more tests on the system and were reassured that it would be able to cope. While ETRMA acknowledged that it had no visibility on the full extent of the system’s outreach, the body noted substantial challenges in the IT system on their own “would not justify delaying the regulation.”
  
  (Read the original article here)

• Squire Patton Boggs, one of the world’s leading law firms, has published the following comments:
  
  “until a new proposal is officially tabled and adopted, companies should continue preparing for compliance as originally scheduled. Stakeholders are advised to stay informed and ready to adapt, not only to a potential change in timeline but also to possible amendments in how the EUDR will be implemented.”
  
  (Read the original article here)
  
  
• 19 major international food industry operatos, including Nestlé, have signed a letter to Commissioner Jessika Roswall expressing concern about the consequences of a possible delay, stating that it “puts at risk the preservation of forests worldwide" and "undermines trust in Europe’s regulatory commitments".
  
  (Read the original English article here)
  
  

Conclusions

Public commentary has included both critical and supportive views regarding a possible delay. Some stakeholders emphasize the need for system readiness, while others stress predictability and the protection of existing investments. The corporate positions outlined above remain in force, and no announcements of halting preparations have been made.

A delay to the agreed timeline would require approval from both the European Parliament and the Council, and no timetable has yet been set for such a proposal. The approval of a proposal would not be guaranteed either; the institutions may either accept or reject it. Until the EU officially confirms a decision, the current deadlines remain valid.

For example, Commission Vice-President Teresa Ribera has stated that IT system issues are not a sufficient reason for further delaying the application of the deforestation regulation. Internal disagreements within the EU may mean that a decision on a possible delay – whether approved or not – may itself be delayed, as happened last year, when the Commission only announced the previous postponement at the end of December 2024.

Even if the EUDR application timeline changes, Finnish retail, food, and forest sector operators are still developing their traceability and responsibility processes according to original plans. Supplier traceability and product origin data requirements should therefore be taken into account in preparations regardless.

Business risks linked to insufficient EUDR readiness

There is currently a lot of uncertainty around the EUDR timeline and each company should assess the related risks from its own perspective. Key risk factors if application begins under the current timeline without adequate preparations include:

• Restricted market access: Buyers require supply chain traceability (DDS). Without this, products may be removed from assortments, deliveries rejected, or sales suspended.
• Customs and regulatory controls: Missing declarations, geolocation/polygon data, or other documentation will prevent products from passing inspections and entering the market.
• Supplier networks: Onboarding suppliers, collecting responsibility data, and verifying documents takes time. Last-minute action may not succeed.
• IT systems and integrations: Customers are already testing DDS data transfers and integrations. Companies not participating now may not have enough time before year-end.
• Operational risks: Time pressure increases the likelihood of errors and extra costs.
  
  

What happens if your customers continue preparing for EUDR and you don’t?

Even if the EUDR compliance deadline is pushed back, large buyers and retail chains may still require suppliers to provide origin and responsibility data according to their planned timelines. Traceability, transparency, and sustainability have been central themes in the strategies of most major corporations for years, with related projects long under development. While these requirements are designed to align with EUDR obligations, nothing prevents companies from applying them to their suppliers with the originally planned schedule – whether the EUDR takes effect on December 30, 2025, or later.

For many companies, this is a critical theme around which significant investments have already been made. Postponing these plans because of EU Commission timeline changes would not be rational in most cases.

If companies suspend preparations and wait for the Commission’s official stance, by the time it arrives it may already be too late to respond to customer demands. The only way to mitigate this risk is to continue preparations now and engage directly with major customers about their expectations and plans regarding the issue.

Bluugo’s recommendation for moving forward

The risks outlined above can realistically be managed only by continuing EUDR preparations during the current year. Of course, this also entails uncertainties: what if implementation is delayed significantly or requirements are changed? We understand that the situation is very challenging for many companies. We are monitoring developments daily and are ready to offer our clients flexible models to continue preparations as safely as possible, despite the uncertainty and open questions created by recent news