Potential Delay to the Implementation of the European Deforestation Regulation

The European Commission has proposed delaying the implementation of the European Deforestation Regulation (EUDR) by 12 months. However, the proposal for a delay would need to be agreed upon by the European Parliament and the 27 member states.

Under the existing proposals, all products whose supply could be implicated in the action of deforestation through the supply chain will need to have mechanisms in place to ensure that the products placed on the EU markets are free from deforestation. Large companies would have needed to be in compliance by the 30^th December 2024 and smaller companies by 30^th June 2025.

This will impact timber in the furniture supply chain, but in principle, it is an extension of the requirements that have been in place through the EU Timber Regulation (EUTR), which it repeals. It will be expanded to include other products and materials that can be sourced from regions associated with deforestation, including leather and rubber. A number of food items, such as cocoa, coffee, soy, and palm oil, are also within the scope of the new regulation.

In response to concerns raised by some supplier countries, member states and impacted industries, a proposal to delay implementation has been introduced. Under this proposal, the requirement for large companies to demonstrate compliance will be 30^th December 2025, and for small companies, it will be 30^th June 2026.

For the purposes of this regulation, the standard EU definition of an SME should be used: an organisation with fewer than 250 employees and an annual turnover of less than €50 Million or an annual balance sheet below €43 Million.

As this proposal is subject to ratification, impacted organisations should continue to plan for the original timescales, but be aware that there may be a 12 month delay in implementation.

For further information about impacted supply chains, please contact John Hubbard.