ANY prospects of the European Union Deforestation Regulation being postponed for a further 12 months appear to have been put to rest, following recent statements made by EU officials in Luxembourg.
In a recorded interview (click link below to access) the Chair of the European Parliament Environment Committee, Commissioner Jessika Roswall, explains the proposed changes she expects will be implemented with the EUDR legislation.
The latest proposal has been put forward as an alternative to the previous September proposal for a 12-month delay to the scheduled start of EUDR, which was attributed to issues with the EUDR IT system that would not be addressed before the regulation went into force.
“We remain very committed to that EUDR objective,” Commissioner Roswall says in the recorded briefing.
Earlier, there had been speculation in Australia and elsewhere that the EU might delay the implementation of the plan for another 12 months, having already done so once, a year earlier. Another theory was that the EU would pursue the EUDR objective and deadline for imported (non-EU) goods only, but would give food producers in EU member-states an additional year’s grace.
Both now appear extremely unlikely.
During the briefing, Commissioner Roswall suggests the legislation will enter into force as planned on 1 January 2026.
Among the key points:
- Large and medium-sized companies will have to submit documentation from 1 January, but there will be a phased introduction over six months. During the phase-in period EU country authorities will not be required to carry out checks, and can only issue warnings. No penalties or sanctions will be prescribed during this first six-month phasing in period, ending 30 June. What remains unclear from the briefing is whether larger operators (ie meat processors) must submit a DDS from 1 January, or whether they could wait until the end of the six month phase-in period, until it is compulsory.
- Micro/small companies will not have to submit a DDS until one year later. The proposal includes a six-month delay for micro and small enterprises importing relevant products and proposes changes to simplify the due diligence and declaration requirements.
- Downstream operators will not be required to submit a further DDS. They can use the DDS Reference Number from the first operator to place goods on the market.
Commissioner Roswall said it was unlikely that the EU would introduce a ‘Negligible Risk’ category under EUDR, as this would require considerable work updating the legislation, and there was only two months to go before the program is due to enter into force.
The latest proposal outlined above will now be discussed by the EU Parliament and Council and could still be subject to changes.
In the meantime, Australian red meat industry players suggest the least risky approach is to prepare for the current implementation date of 1 January. That means product on the water now destined for EU markets would have to be covered by a Due Diligence Statement.
The proposed six months’ phase-in after 1 January means product on the water from March-April next year would be exposed to penalties or sanctions likely from 1 July, unless EUDR compliant.
As of September, less than half of Australia’s EUCAS-eligible livestock producers had signed up to the Integrity Systems Company’s EUDR Geolocation sharing tool, with slow adoption and resistance from producers making it difficult for exporters to meet EUDR requirements before the 1 January deadline.
Similarly, Australian cattle hides either destined for direct sale into EU countries or sold into China for processing into leather goods ultimately bound for the EU, also remain exposed to the EUDR legislation. Worth noting, this applies to hides from all Australian cattle – not specifically to EUCAS eligible herds for boxed beef sales.
Producer comments in Australia claiming that they ‘got no incentive’ for becoming compliant with the EUDR requirements around geolocation ignored that fact that the EU remains the highest-paying market for Australian beef.
“The option is, selling that product into another market at a cheaper price,” Beef Central was told by a trade source. “That then gets reflected in livestock price – it’s the price of doing business.”
While the United Kingdom is no longer part of the EU bloc there has also been some comment recently that some UK-based supermarket chains (Tesco is one example) are likely to request the EUDR requirement on imported beef from Australia and elsewhere from next year, in line with the European Union’s objectives.
Leather manufacturers urge the EU to ‘stop the clock’
In other EUDR developments this week, the Confederation of National Associations of Tanners and Dressers of the European Union has issued a ‘Stop the Clock’ plea over the January 1 deadline.
“After initially announcing a postponement in September 2025, the European Commission now proposes to move a new EUDR into full application within just two months — a reversal that risks undermining confidence in the EU regulatory process,” the COTANCE body said.
“The concerns of stakeholders span from proposed timelines creating significant uncertainty for European leather manufacturers — from large downstream industries, which will be unable to re-adapt their IT systems once again, to small and micro operators, who will face an even greater administrative burden for managing themselves the data load of the number of Due Diligence Statement (DDS) reference numbers accumulating along the value chain,” the body said.
The Commission’s amendment also failed to meet a key legal requirement — the scope-related Impact Assessment under Article 34, COTANCE said.
“This impact assessment was meant to verify whether the list of products should be amended or extended. Originally due in June 2025, it has now been cancelled altogether and replaced by the “general review” in 2030, five years after implementation. This mal-administration deprives sectors such as leather of their legal right to evidence-based policymaking – as leather-impacts had never been assessed so far – and undermines the EU principles of Better Regulation.”
COTANCE said the inclusion of hides, skins and leather in the scope of the EUDR was made without a proper impact assessment.
Authoritative scientific evidence has confirmed that leather is not a driver of deforestation. Leather is a by-product of the meat and dairy sectors and no cattle are raised for their hides. Leather-making contributes to circularity by valorising resources that would otherwise become waste.”
COTANCE secretary general, Gustavo Gonzalez-Quijano, said the European leather industry fully supported the fight against deforestation.
“But sustainability cannot be achieved through regulations that disregard the realities on the ground. We call on the Commission to take a step back, listen to evidence, and ensure that EUDR implementation is based on facts, not assumptions. The time has come to stop the clock and get this regulation right.”
“COTANCE reaffirms its commitment to sustainability, transparency, and responsible supply chains. However, a regulation that is not evidence-based, not workable, and not fair serves neither the environment nor the European economy.”