With just over three months until compliance with the EU Deforestation Regulation (EUDR) is scheduled to begin, the European Commission has signaled that it may seek a further one-year extension.

In a September 23 letter, Commissioner Jessika Roswall (Environment, Water Resilience, and a Competitive Circular Economy) informed the European Parliament and Council that the Commission’s IT system for handling EUDR-covered transactions is not expected to manage the full volume of activity.

The EUDR applies to imports and exports of cattle, cocoa, coffee, oil palm, rubber, soy, and wood, along with a wide range of derived products.

From the Commission’s letter:

“This will very likely lead to the system slowing down to unacceptable levels or even to repeated and long-lasting disruptions… Operators would be unable to register as economic operators, introduce their Due Diligence Statements, retrieve the necessary information from the IT system, or provide the necessary information for customs purposes where relevant.”

The Commission concluded that, despite mitigation efforts, there are no sufficient guarantees that the IT system will sustain expected loads by the current compliance date. A one-year postponement is therefore under consideration to address these risks.

What Comes Next

The Commission is expected to propose a “stop the clock” measure in the coming weeks. For rapid approval, this proposal is likely to be narrowly focused on timing only, rather than substantive changes to the EUDR. Other ongoing initiatives, however, may lead to further modifications.

Rising Pressure for Delay and Simplification

The EUDR has faced sustained criticism since adoption, particularly around administrative feasibility and supply chain traceability. Recent developments include:

• Simplification measures (April 2024): The Commission issued updated FAQs and guidance, which it estimates will reduce compliance costs by 30%.

• Environmental Omnibus Proposal: A call for evidence closed September 10 on a broader EU simplification package, which could include EUDR adjustments.

• Parliament resolution (July 2025): The European Parliament adopted a non-binding resolution questioning the Commission’s risk classifications and urging a review.

• Member state concerns: At the May AGRIFISH Council, 11 member states submitted a paper calling for EUDR simplification and postponement. In July, 18 Agriculture Ministers echoed those concerns in a joint letter, noting disproportionate burdens on countries with strong forest protections and the practical challenges of full traceability.

• International trade tensions: In August, the U.S. and EU agreed to address U.S. concerns under a new trade framework, acknowledging that U.S. commodity production poses negligible deforestation risk and should not face disproportionate barriers under the EUDR.

Outlook

EUDR compliance was already delayed once, and with the current IT infrastructure still not ready, another delay appears likely. Even so, the core obligations of the EUDR remain intact: companies in scope must eventually provide geolocation-based due diligence to demonstrate that covered products are not linked to deforestation.

For companies, the prudent move is to continue preparing systems, supply chain traceability, and due diligence processes, while monitoring timing changes closely. An additional one-year delay may ease short-term pressure, but it does not change the strategic need to comply with the regulation once it takes effect.