EUDR Postponement in 2026: The 5 Most Dangerous Misconceptions

Summary for Decision-Makers

The effective date of the EUDR (EU Deforestation Regulation) has been set: Starting December 30, 2026, large andmedium-sized companies must comply with due diligence requirements. A third postponement has not yet been decided upon nor is it currently being considered. The simplifications introduced in December 2025 were the political trade-off for a fixed start date, not the beginning of further delays.

The most common misjudgments concern precisely the issues that will determine whether the regulations are implemented on time: the supposed next postponement, an alleged extension for medium-sized companies, the underestimation of due diligence as“merely a formality,” the special rules regarding wood, and the mistaken assumption that only large importers are affected.

In practice, this means that the additional time is preparation time—not a green light. Anyone who doesn’t use the remaining months to implement the changes won’t be ready by the end of 2026 either. This is primarily because the most time-consuming steps depend on third parties (your own suppliers) and cannot be made up for at short notice.

Why Dangerous EUDR Misconceptions Are Piling Up Right Now

The EUDR was adopted on June 29, 2023, and has been in effect since then; however, its effective date has been postponed twice: to December 2024 and again to December 2025 by Regulation (EU) 2025/2650. Both times, the postponement was accompanied by intense public debate, and both times it was announced well in advance. This history shapes public expectations: If it has been postponed twice, why not a third time?

In addition, the revision in December 2025 not only postponed the deadline but also simplified certain provisions. These included, for example, reduced reporting requirements for downstream actors, the option of a simplified declaration for certain market participants, and the removal of individual product groups from Annex I (for example, certain products of the graphic arts industry under “ex 49”). In the eyes of many companies, “postponement” and “simplification” merge into a vague sense of relief. It is precisely this feeling that provides fertile ground for the following five misconceptions.

Misconception 1: “The EUDR will just be postponed again anyway”

What many people assume

The logic sounds plausible: The launch date has been postponed twice, the business community has complained, so the same thing will happen a third time. Anyone who thinks this way is quietly putting off their own preparations until next year.

Why that doesn't work

There is currently no proposal for a third postponement, no parliamentary majority, and no ongoing legislative process. The two previous postponements were each decided through the regular legislative process and with months of advance notice. None of that is evident at this time.

The risk: a plan that cannot be insured

Anyone who bases their preparations on the assumption of a third postponement isn’t following a strategy—they’re taking a gamble. If the postponement does not happen—and all signs point to that—there won’t be enough time to catch up on time-consuming steps such as supplier data, geographic data, and system setup. The problem isn’t the due diligence declaration itself, but the lead time it requires.

Misconception 2: “Medium-sized companies have until June 2027”

Where the Misconception Comes From

Two dates frequently appear in communications regarding the postponement: December 30, 2026, and June 30, 2027. This gives the impression of a phased deadline from which medium-sized companies also benefit. That is incorrect.

What Actually Applies

The extended deadline of June 30, 2027, applies only to two groups: micro and small enterprises as defined by the Accounting Directive, as well as certain individuals. It does not apply to medium-sized enterprises. Like large enterprises, they are subject to the December 30, 2026, deadline. The decisive factor here is the status as of the cut-off date of December 31, 2024. Any entity established as a micro or small enterprise after that date is also subject to the earlier deadline.

Who Needs to Be Especially Careful Right Now

Companies that fall in the gray area between “small” and “medium-sized” are particularly at risk. In practice, they often assume they are subject to the later deadline, even though they are already considered medium-sized companies and are therefore subject to the December 30, 2026, deadline.

The classification is based on the EU Accounting Directive and relies on three key figures: the average number of employees over the year, total assets, and revenue. A company is considered a small business only if it does not exceed at least two of the following three thresholds: 50 employees, a balance sheet total of 5 million euros, and revenue of 10 million euros. A company that exceeds two of these three thresholds is no longer considered a small business but is classified as at least a medium-sized enterprise.

Misconception 3: “The EUDR is just another form”

The Misconception

Because the process culminates in a declaration of due diligence in the EU information system, the EUDR is often reduced to a mere bureaucratic formality: fill out the form, submit it, and you’re done. The declaration is indeed submitted quickly, but it is just the tip of the iceberg of a much greater effort.

Why the Statement of Due Diligence Is Just the Tip of the Iceberg

The key requirements of the EUDR go far beyond simply filling out a form. The actual challenging steps come before the declaration: collecting geodata on production areas, ensuring complete traceability from the product back to its area of origin, gathering and verifying documentation throughout the supply chain, and conducting a robust risk assessment.

The Underestimated Time Factor

The critical issue lies outside one’s own four walls. Much of the required data comes from suppliers, some of whom are several levels down the supply chain. Experience shows that such responses take weeks, not days. And the closer the deadline gets, the more the suppliers’ inboxes fill up with the same requests. Exactly what data needs to be obtained from whom, and how to structure the requests, is a topic in itself and would go beyond the scope of this discussion. At this point, only one thing is crucial: Anyone who waits until shortly before December 30 has already missed the most time-sensitive step.

Misconception 4: “We also have until 2027 when it comes to wood products”

The special rule regarding timber and the old EU Timber Regulation

There is an important exception for wood and wood products that is easily overlooked. Products that were previously covered by the EU Timber Regulation (EUTR, Regulation (EU) No. 995/2010) are exempt from the later deadline.

Why December 30, 2026, Already Applies Here Even for Small Businesses

The rationale behind this special rule is understandable. Even before the EUDR, timber and timber products were subject to their own due diligence regime, the EU Timber Regulation (EUTR). Companies that trade in these products have therefore been aware of the traceability requirement since before the EUDR came into effect. The legislature therefore saw no reason to grant them an additional grace period. Anyone who was already subject to due diligence requirements under the EUTR remains so seamlessly under the EUDR.

For the affected companies, this is a dangerous trap. A small business that markets furniture, lumber, paper, or other wood products intuitively assumes it falls under the later deadline because, based on its size, it is a small business. In fact, however, it is already subject to the December 30, 2026, deadline. This shortens the available preparation time by half a year, without the business even realizing it.

Misconception 5: “This only affects large importers”

The Assumption

Those who do not import goods themselves but resell them within the EU often feel that this does not apply to them. The idea is that responsibility lies solely with the party that first places the product on the EU market.

What downstream market participants and traders must still do

The revision of the EUDR now distinguishes between upstream and downstream market participants. The obligations for downstream actors have been reduced, but not eliminated. Specifically, this means that downstream market participants and distributors must continue to record and retain the reference numbers of the due diligence statements. They must be able to provide these numbers upon request. If the required documentation is missing, the goods may, under certain circumstances, no longer be placed on the market.

Why “our suppliers will take care of it” isn’t enough

Relying blindly on suppliers to comply with regulations is risky: If the correct reference number is missing or incorrect, the retailer will be left without proof. The obligation to properly document one’s own purchases cannot be delegated to the supplier; it remains the retailer’s responsibility.

Conclusion

All five misconceptions boil down to the same error in reasoning: interpreting the postponement as a signal that the danger has passed rather than as a chance to prepare. The December 30, 2026, deadline stands; it also applies to medium-sized companies; due diligence is more than just filling out a form; wood products are subject to special rules; and retailers also have obligations. Those who are aware of these points and take them seriously will gain an edge over those who are hoping for the next postponement.

The most challenging part of the EUDR is not understanding the legal requirements, but rather putting them into practice: collecting geodata, gathering supplier documentation, assessing risks, and submitting due diligence statements on time and in a manner that stands up to audit scrutiny. All of this must be done across the entire supply chain and on a large scale. This is exactly where our software solution comes in: The EUDR module of the lawcode Suite maps the entire process—from data collection to submission to the EU information system—in a structured and audit-ready manner.