EUDR Will Not Be Delayed — The European Commission Confirms Enforcement for 2026

The European Commission has confirmed that the EU Deforestation Regulation (EUDR) will take effect as planned. Large and medium-sized companies must comply by 30 December 2025, while smaller operators follow in December 2026. Instead of a delay, the EU will simplify reporting obligations and offer a six-month leniency period in 2026.

From uncertainty to confirmation

After months of confusion and lobbying, the European Commission has made its position clear: the EUDR will not be delayed.

Earlier this autumn, several media outlets, industry groups, and national governments had hinted that the Commission was preparing to push back the start of the regulation, potentially to 2027, due to concerns that the TRACES NT system, the digital platform handling deforestation declarations, was not ready for the expected volume of data.

Now, the Commission has confirmed the opposite. Following internal consultations with EU member states and the European Parliament, Brussels announced on 21 October 2025 that it will proceed with enforcement as scheduled, making limited but significant technical adjustments to ease the transition.

The decision marks a major turning point for the thousands of companies that had put their compliance projects on hold, expecting a formal delay.

EUDR’s scope: protecting forests, globally

The EU Deforestation Regulation is one of the most ambitious sustainability laws ever passed by the European Union.
Its purpose is simple but far-reaching: to ensure that goods sold in the EU are deforestation-free and legally produced.

The regulation covers seven major commodities known to drive deforestation: cattle, cocoa, coffee, oil palm, rubber, soy, and wood.
It also extends to a long list of derived products, including paper, printed materials, furniture, and leather goods.

This broad coverage means that the regulation reaches far beyond the traditional forestry or agricultural sectors.
For publishers, book manufacturers, and packaging companies, it introduces a new compliance layer, requiring traceability and documentation of raw material origins, even when those materials come through long and complex supply chains.

EUDR will not be  delayed – but have a smarter implementation

According to the official EU press release (IP/25/2464) and detailed analyses in Politico, Lexology, and FoodNavigator, the Commission abandoned its delay plan in favour of a simplified reporting model.

In the original design, companies would have had to submit deforestation-related data repeatedly through TRACES NT, at various stages of the supply chain.

Now, under the simplified model, companies will report product origin data once, at the point when their products first enter the EU market.

This change achieves several objectives:
• It reduces the total number of reporting entities by an estimated 9,000 companies, mainly in downstream manufacturing.
• It prevents duplication of data submissions within complex supply chains.
• And crucially, it avoids system overload in the first months of implementation.

As EU Environment Commissioner Jessika Roswall explained in the Commission’s announcement:

“We believe these targeted adjustments will solve the IT challenges and allow for a smooth start. The core principle of the regulation, preventing deforestation, remains untouched.”

Two key dates: December 2025 and December 2026

The new timeline now stands as follows:

• 30 December 2025 – Enforcement begins for large and medium-sized operators and traders. These include most EU importers, major distributors, and established suppliers that place regulated products on the EU market.

• 30 December 2026 – Compliance begins for micro and small enterprises. The six-month delay for smaller operators aims to give them additional time to adjust internal processes and establish traceability systems.

To further ease the transition, the Commission has introduced a leniency period. For the first half of 2026, companies will not face penalties for incomplete or delayed declarations, provided they demonstrate good-faith efforts to comply.

This period is not a suspension of the law, merely a buffer to fine-tune systems and data pipelines before full enforcement.

Why the Commission changed course

Internally, the Commission faced intense pressure from two directions.

On one side, environmental NGOs and Member States such as Germany, France, and the Netherlands pushed to maintain the schedule, warning that a delay would undermine Europe’s global climate leadership and credibility.

On the other, industry associations, particularly in agriculture, publishing, and logistics, warned that the TRACES NT system’s technical limitations and unclear guidance for operators risked “chaos by compliance.”

The compromise is strategic:
• No delay, to preserve the EU’s commitment to deforestation-free trade.
• Simplified reporting, to accommodate the system’s technical capacity.
• Temporary leniency, to allow businesses time to adapt.

As Politico framed it, this was “a rare Brussels U-turn that pleased no one fully but kept the regulation alive.”

For non-EU publishers, clarity comes with urgency

For companies in the publishing, printing, and packaging sectors outside the EU, this announcement removes any lingering doubt.

The paper and wood-based products used in books, magazines, and other printed materials fall squarely within the EUDR’s scope.
This means that every book, catalogue, or printed product entering the EU market must be backed by data proving that its raw materials are deforestation-free and traceable to legal sources.

Many non-EU publishers have until now assumed that paper suppliers or printers in Europe would handle these obligations on their behalf.
That assumption no longer holds.

Under EUDR, the responsibility lies with the first entity placing the product on the EU market.
For foreign publishers selling directly into the EU, for example through Amazon, Ingram, or their own webshops, that responsibility may fall on their own organisations or their European distributors.

It’s important to understand that even if you don’t sell directly to the EU but distribute through partners or intermediaries, you may still be affected. Even when you are not directly obligated under the EUDR, your distributors are, and they are unlikely to accept your books for EU distribution unless you can provide the required Due Diligence Statement (DDS) numbers.

If the due diligence statement is missing, the product cannot legally be marketed or sold within the EU.

Practical implications for publishing companies

For non-EU publishers, the EUDR introduces three key obligations:

1. Traceability:
   You must know the origin of all paper or wood-based materials used in your books or printed products, including the geolocation of the forest plot where the timber was harvested.

2. Documentation:
   All relevant supplier information, from mills and printers, must be recorded and made available for inspection through the TRACES NT system.

3. Due diligence statements:
   Before a product enters the EU market, a formal statement must be filed confirming that the product does not contribute to deforestation.

Even if you outsource production to third parties, you remain responsible for ensuring that these data and declarations exist.

How EAS supports publishers with EUDR compliance

EAS has developed a fully automated EUDR compliance system tailored for the publishing and print industries.

Our platform:
• Connects directly with the TRACES NT environment.
• Collects supplier and origin data automatically through structured templates.
• Generates and maintains all due diligence statements in accordance with the Commission’s requirements.
• Provides risk evaluation tools to identify and flag potential high-risk suppliers or countries of origin.
• Integrates with your existing catalogues and ISBN databases, enabling full traceability without disrupting your existing sales channels.

For global publishers, EAS also provides centralised supplier management, ensuring every new title or reprint automatically meets EUDR requirements without manual input.

Market reality: early movers will win

The Commission’s confirmation has already triggered a wave of renewed activity. According to EAS onboarding data, several distributors and printing groups restarted paused EUDR projects within hours of the announcement.

The pattern is clear: companies that prepared early, collecting supplier data, mapping material origins, and validating geolocation data, will face minimal disruption. Those that delayed will now compete for limited technical and advisory capacity as the 2025 deadline approaches.

For publishers, the message is particularly pressing:
EUDR is not a forestry regulation, it’s a trade regulation. Failure to comply will not only risk penalties but can block access to the EU market entirely.

A transition period, not a pause

Some reports have referred to the 2026 leniency window as a “transition year.”

This is misleading.

The regulation enters into force fully in December 2025. The six-month period is meant solely to give authorities and companies time to stabilise reporting systems.

By end of 2026, all operators, large or small, are expected to have full compliance procedures in place. The Commission has made clear there will be no further extensions.

Conclusion: EUDR enters a decisive phase

The European Commission’s decision brings long-awaited clarity.
The EUDR will take effect as planned:

• 30 December 2025 for large and medium-sized companies
• 30 December 2026 for smaller operators

The policy intent is unchanged, only the implementation path has been adjusted.
For the publishing and print industries, this is both a challenge and an opportunity: to modernise supply chains, demonstrate environmental responsibility, and secure continued access to the world’s largest consumer market.

EAS stands ready to support global publishers and distributors through this transition with automation, compliance management, and expert guidance.

EUDR is not delayed — it’s simplified. The time to prepare is now.