The European Union’s landmark anti-deforestation law has undergone yet another round of delays and simplifications. Initially passed in 2023, the European Union Deforestation Regulation (EUDR) is part of the EU’s broader effort to sever links between European consumption and global deforestation. Under the latest round of changes, the date of applicability was pushed back by one year and large companies will now have until December 30, 2026 to comply and an additional 6-month extension was granted for micro and small operators who will now have until June 30, 2027.
What else has changed?
Besides the delays in applicability, several important simplifications were also made to EUDR.
1. The revised EUDR places the responsibility of submitting due diligence statements solely on the operator first placing the product on the EU market. Downstream actors, such as retailers or manufacturers, will not have to file their own submission and instead will only have to retain the reference numbers linked to upstream declarations.
2. For micro and small primary operators, compliance will be even more streamlined. Instead of the requirement for repeated declarations, these companies will only have to submit one declaration in the EU IT system.
3. Specifically for printing, products that fall under HS code 49 are no longer in the scope of the regulation. This includes books, newspapers, commercial printing products, and advertising materials. However, this does not apply to products that fall under HS code 48 like printed packaging, labels, wallpaper, and stationery.
These changes to EUDR are intended to reduce administrative duplication while preserving the traceability of the products.
What remains the same?
Despite the delays and simplifications, the core requirements of EUDR remain unchanged. Companies that are placing or exporting covered products (i.e., oil, beef, timber, cocoa, wood, rubber, soy, and certain derivatives) still must prove that they did not contribute to deforestation or forest degradation after 2020. Mandatory due diligence requirements, like traceability to the plot of land where the product came from, remain front and center.
The latest round of delays for EUDR have been met with mixed reviews. On one side, it reflects the concerns of some member states, companies, and trading partners over the EU’s readiness, especially of the EU IT system’s capacity to handle the volume and complexity of data required. However, companies that have spent years preparing for the regulation expressed some frustration as they see this as a penalization for those who acted early. They argue that a clearly defined grace period would have allowed firms to begin implementation while still giving the EU time to get their computer systems in place.
There is still some uncertainty as to what exactly EUDR will look like in its final form. The European Commission is required to carry out a simplification review of EUDR by April 30, 2026. Based on that review, a report will be submitted to the Parliament and Councill accompanied by a legislative proposal, if necessary.
For U.S. printers, the latest EUDR changes significantly reduce near-term regulatory impact and compliance risk. Most notably, printed products such as books, newspapers, and commercial print are now excluded from the regulation. However, printers involved in printed packaging, labels, or other products may still be affected and should continue monitoring compliance obligations. While the delayed implementation provides additional time, U.S. printers with EU-facing supply chains should remain attentive to supplier due diligence expectations, especially for covered raw materials, as traceability and deforestation-free sourcing remain central to the regulation.
In this article, Sara Osorio, Coordinator, EHS Affairs, PRINTING United Alliance, discusses the recent changes to the European Union Deforestation Regulation. More information on sustainability can be found at Business Excellence-EHS Affairs, or reach out to Sara directly if you have questions about how these issues may affect your business: sosorio@printing.org.
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