Regulation (EU) 2024/3234: 12-month postponement…

We deferred our EUDR rollout once already — what counts as live now and what bites first?

Regulation (EU) 2024/3234 pushed the EUDR date of application to 30 December 2025 for operators and traders and to 30 June 2026 for micro and small undertakings — non-SME companies are therefore in full live mode and Compliance owns due diligence statements as the first failure point.

Short Answer

Regulation (EU) 2024/3234 is a one-article amendment to the EUDR (Regulation (EU) 2023/1115). It postpones the date of application of the operator and trader obligations by 12 months [Art. 1(3)] and adjusts the linked dates for the repeal of Timber Regulation (EU) No 995/2010 [Art. 1(2)] and for the country risk classification deadline [Art. 1(1)]. It does not relax any substantive obligation — due diligence under Art. 8 EUDR, the deforestation-free condition under Art. 3 EUDR and the penalty regime under Art. 25 EUDR remain unchanged. Companies that paused their EUDR programme in late 2024 are therefore now operating against a live regime, not a draft.

Who is affected

All operators and traders placing or making available on the Union market or exporting cattle, cocoa, coffee, oil palm, rubber, soya, wood and products derived from them (Annex I EUDR). Micro and small undertakings within the meaning of Art. 3(1) and (2) of Directive 2013/34/EU, established as such by 31 December 2020, receive an additional six-month grace period until 30 June 2026 [Art. 1(3)]. Products previously covered by the Annex to Regulation (EU) No 995/2010 are excluded from that grace period [Art. 1(3)].

Deadline

30 June 2026 — application date for micro and small undertakings (about seven weeks from today). The general application date of 30 December 2025 has already lapsed; non-SME operators and traders must already be filing due diligence statements in the EU information system [Art. 1(3)].

Risk

Regulation (EU) 2024/3234 itself imposes no penalty — but once live, Art. 25 EUDR sets a maximum fine of at least 4 % of total annual Union turnover for legal persons, plus confiscation of relevant products and the revenues derived from them, temporary exclusion from public procurement and from access to public funding, and a temporary prohibition from placing or making available relevant products on the Union market. Customs authorities can block placement of non-compliant shipments under Art. 26 EUDR.

Proof

Legal status

• In force
• as of 2026-05-10
• Original version of 19 December 2024

Primary sources

• EUR-Lex — Postponement regulation amending EUDR (32023R1115)
• European Commission — EUDR — Commission guidance on EUDR implementation

What to do now

Legal / DPO

•Confirm that the EUDR live-date for the company is 30 December 2025 and update any internal legal opinion, board memo or supplier notice that still references the original 30 December 2024 date [Art. 1(3)].
•Map the company's status under Directive 2013/34/EU as of 31 December 2020 — only undertakings classified as micro or small at that cut-off keep the 30 June 2026 grace period [Art. 1(3)]; later restructurings or downsizing do not move the goalposts.
•Re-baseline contractual EUDR clauses with suppliers and customers against the postponed dates and the unchanged Art. 8 EUDR due diligence allocation, in particular indemnities and rejection rights for non-compliant goods placed from 30 December 2025.

Compliance

•Verify that due diligence statements under Art. 8 EUDR have been registered in the EU information system for every relevant commodity placed on the market or exported since 30 December 2025 [Art. 1(3)] (using the system established by Commission Implementing Regulation (EU) 2024/3084).
•Treat the country risk list under Art. 29(2) EUDR as live since 30 June 2025 [Art. 1(1)] and refresh the country-of-production risk profile for cattle, cocoa, coffee, oil palm, rubber, soya and wood sources accordingly.
•Document the transition for legacy timber: timber and timber products produced before 29 June 2023 and placed on the market from 30 December 2025 stay under Regulation (EU) No 995/2010 until 31 December 2028 [Art. 1(2)] — keep the 995/2010 due diligence files alive until then and migrate them to Art. 3 EUDR before 31 December 2028.

IT / Security

•Integrate the EUDR information system (Commission Implementing Regulation (EU) 2024/3084) with master data, ERP and product information systems so that due diligence statements can be filed at scale rather than as single uploads [Art. 1(3)].
•Provision role-based access in the EUDR system for operators, authorised representatives and (where used) customs brokers, and log every statement submission and amendment for audit [Art. 1(3)].
•Lock retention of geolocation evidence (plot polygons, harvest dates, supplier identifiers) at least until the longer of (a) the five-year retention required by Art. 8 EUDR or (b) 31 December 2028, the end of the legacy 995/2010 timber regime [Art. 1(2)].

Product / Engineering

•Re-run the Annex I EUDR scope check on the live SKU catalogue for cattle, cocoa, coffee, oil palm, rubber, soya and wood — products in scope cannot be placed or made available on the Union market without a due diligence statement after 30 December 2025 [Art. 1(3)].
•For SME-status group entities benefiting from the 30 June 2026 deferral, freeze and tag the in-scope SKU list explicitly so that finance, tax and customs flows do not trigger the parent's earlier obligation [Art. 1(3)].
•Plan a controlled cut-over for legacy timber stock produced before 29 June 2023: products placed on the market from 30 December 2025 keep running on Regulation (EU) No 995/2010 until 31 December 2028, then must comply with Art. 3 EUDR [Art. 1(2)].

Key Terms

EUDR (Regulation (EU) 2023/1115): EU Deforestation Regulation. Prohibits placing or making available on the Union market, or exporting from the Union, certain commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) and derived products unless they are deforestation-free, legally produced and covered by a due diligence statement.
Due diligence statement (Art. 8 EUDR): Mandatory declaration, submitted into the EU information system before a relevant product is placed on the Union market or exported, in which the operator confirms that due diligence was carried out and that no or only negligible risk of non-compliance was found. Identified by a unique reference number.
Date of application: Date from which the substantive obligations of an EU regulation become enforceable, distinct from entry into force. For the EUDR after Regulation (EU) 2024/3234, the date of application of operator and trader obligations is 30 December 2025; for micro and small undertakings, 30 June 2026.
Operator (EUDR): Any natural or legal person who, in the course of a commercial activity, places relevant products on the Union market or exports them from the Union. Operators carry the primary due diligence obligation under Art. 8 of Regulation (EU) 2023/1115.
Trader (EUDR): Any person in the supply chain other than the operator who, in the course of a commercial activity, makes relevant products available on the Union market. Non-SME traders are subject to the same due diligence duties as operators; SME traders carry lighter information-keeping duties.
Micro and small undertaking (Directive 2013/34/EU): Undertaking that, on its balance-sheet date, does not exceed the thresholds in Art. 3(1) (micro) or Art. 3(2) (small) of Directive 2013/34/EU on balance sheet total, net turnover and average employee headcount. The EUDR deferral to 30 June 2026 only covers entities classified as such by 31 December 2020.
Country risk classification (Art. 29 EUDR): Three-tier ranking — low, standard or high risk — assigned by the Commission to countries or parts thereof, by means of implementing acts, no later than 30 June 2025 after Regulation (EU) 2024/3234. It drives the depth of due diligence and the simplified due diligence option for low-risk sources.

Frequently Asked Questions

Did Regulation (EU) 2024/3234 change any substantive EUDR obligation?

No. The amendment only moves dates: the date of application of operator and trader obligations is postponed by 12 months [Art. 1(3)], the country risk classification by 6 months [Art. 1(1)], and the linked repeal of Regulation (EU) No 995/2010 is adjusted accordingly [Art. 1(2)]. The substantive due diligence, deforestation-free condition and penalty regime in Regulation (EU) 2023/1115 are untouched.

What is the new EUDR date of application for non-SME operators and traders?

30 December 2025 — Articles 3 to 13, Articles 16 to 24 and Articles 26, 31 and 32 of Regulation (EU) 2023/1115 apply from that date [Art. 1(3)]. As of today (10 May 2026) those obligations are therefore already live and the EU information system is in operation.

Which companies still benefit from the deferred application date of 30 June 2026?

Only operators that, by 31 December 2020, were established as micro-undertakings or small undertakings within the meaning of Art. 3(1) or (2) of Directive 2013/34/EU [Art. 1(3)]. Companies that grew out of that classification later do not get the deferral, and the deferral does not cover products previously covered by the Annex to Regulation (EU) No 995/2010.

When does the Commission's country risk classification under Art. 29 EUDR have to be in place?

By 30 June 2025 — postponed by only six months, so that operators and traders have the country list well in advance of their due diligence go-live [Art. 1(1)]. Until publication of that classification, all countries carry the standard level of risk.

What happens to Regulation (EU) No 995/2010 (the Timber Regulation)?

It is repealed with effect from 30 December 2025 [Art. 1(2)]. However, it continues to apply until 31 December 2028 to timber and timber products as defined in its Art. 2(a) that were produced before 29 June 2023 and placed on the market from 30 December 2025. Such legacy timber must comply with Art. 3 EUDR if placed on the market from 31 December 2028 onwards [Art. 1(2)].

When did Regulation (EU) 2024/3234 itself enter into force?

On the third day following its publication in the Official Journal of the European Union [Art. 2]. It was published in the OJ L series on 23 December 2024, so it entered into force in late December 2024 — before the original EUDR application date of 30 December 2024, exactly as recital 11 required.

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