EU Regulation on Deforestation-free Products (EUDR): What’s next for UK companies?

The Regulation (EU) 2023/1115 on deforestation‑free products (EUDR) was amended on 23 December 2025, just days before it was due to apply. Regulation (EU) 2025/2650 postponed the application of the EUDR for a second time, to 30 December 2026, and introduced targeted simplifications.

Companies that supply in‑scope commodities and products to the EU market – including UK companies – must navigate the evolving regime while continuing to prepare for compliance. This article summarises the latest changes and considers the next steps for UK companies to comply with the EU’s requirements for deforestation‑free supply chains.

Background

The EUDR came into force on 23 June 2023. Its objectives are to minimise the EU’s contribution to global deforestation and forest degradation, and the associated greenhouse gas emissions and biodiversity loss, by eliminating EU consumption of deforestation‑linked products.

Under the EUDR, organisations that place or make available on the EU market, or export, in‑scope commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and certain derived products must comply with due diligence requirements to ensure that those commodities and products are not linked to deforestation or forest degradation after 31 December 2020 and that they were produced in accordance with the laws of the country of production.

The rules were initially due to apply to large companies from 30 December 2024, but a one‑year postponement was adopted in December 2024 following concerns from member states, third countries and industry about readiness for compliance. In December 2025, a further one‑year postponement was adopted, along with targeted revisions intended to reduce the administrative burden for in‑scope companies (particularly downstream actors and small and micro primary operators) and to ensure readiness of the EUDR IT system.

What has changed?

In late December 2025, the following changes were introduced through Regulation (EU) 2025/2650:

• Postponement of the application date to 30 December 2026 for large and medium companies, or to 30 June 2027 for organisations that were micro or small companies on 31 December 2024.
• Removal of certain printed paper products—including books, newspapers and printed pictures—from the scope of the EUDR.
• Only non‑SME “operators” that first place an in‑scope product on the EU market or export it must submit a due diligence statement (DDS) before placing it on the market or exporting it.
• Simplified requirements for micro or small primary operators, who will only need to submit a one‑time “simplified declaration” before placing an in‑scope product on the EU market or exporting it.
• Non‑SME downstream operators and traders are no longer required to submit a DDS. Instead, only the first operator downstream of the primary operator must collect the DDS reference number (or the declaration ID for a simplified declaration). All other downstream operators and traders must comply with simplified registration, information and notification requirements.
• The EU Timber Regulation (Regulation (EU) No 995/2010) will continue to apply for a three‑year transitional period to timber products harvested before the EUDR entered into force (29 June 2023) and placed on the EU market from 30 December 2026. For products harvested before 29 June 2023 and placed on the market from 31 December 2029, the EUDR will apply instead.
• A “simplification review” must be carried out by the European Commission by 30 April 2026 to evaluate the administrative burden and impact of the regulation. This may lead to further revisions.

How are UK companies impacted?

Although the EUDR applies only in EU Member States, UK companies may be affected both directly and indirectly.

The EUDR is expected to apply directly to companies established in Northern Ireland under the UK–EU Windsor Framework, although the extent of its application remains unclear.

England, Scotland and Wales are treated as “third countries”, meaning the EUDR will not generally apply under national laws. However, companies in third countries can fall directly in‑scope—and therefore acquire due diligence obligations—if they import in‑scope commodities or products into the EU market as an “operator”.

Such companies should understand their obligations and prepare to comply by establishing internal due diligence systems, engaging with suppliers and updating their commercial contracts with suppliers and EU customers to support compliance and mitigate the risk of non‑compliance.

Even where UK companies do not fall directly in‑scope, the EUDR is likely to have indirect impacts, as due diligence requirements will be applied up and down supply chains to support the compliance efforts of in‑scope EU companies.

Potential penalties for non‑compliance include suspension or confiscation of products and fines of up to 4% of annual EU‑wide turnover. Although no enforcement authorities will be established in third countries, liability and risk may be flowed down to UK companies from EU customers.

What’s next for UK companies?

As UK companies continue to prepare for compliance, they should monitor further potential changes before the regulation applies.

The European Commission’s upcoming simplification review may lead to further easing of the requirements. The Commission is also expected to adopt a draft Delegated Regulation which, in its current form, would revise the list of in‑scope products in Annex I and introduce exemptions for certain packing materials and containers used to support, protect or carry other products.

The EUDR IT System has been subject to temporary access limitations since 16 February 2026 while updates are implemented. New registrations and submissions are currently suspended. The system is expected to reopen shortly after mid‑April. Operators will need an EORI number issued by an EU Member State or the UK (for NI). UK companies without an EORI may register using a VAT number, National Company Number or Taxpayer Identification Number.

The Commission’s Guidance Document and Frequently Asked Questions have not yet been updated to reflect the recent amendments. Companies should exercise caution and monitor for the updated versions, which may provide welcome clarity on the amended rules.

While there is no equivalent regulatory regime in the UK at present, Schedule 17 of the Environment Act 2021 provides the framework for a “forest risk commodity” regime. Secondary legislation required to activate the regime has been delayed, and the timeline remains unclear.

The Environmental Improvement Plan 2025 states that the Government “recognises the urgency to ensure that UK consumption of forest risk commodities is not driving deforestation overseas”, but no further action has yet been announced.

Conclusion

We help UK companies assess their obligations under the EUDR, navigate the shifting regulatory landscape and prepare for compliance as part of our ESG legal services. Please contact Michael Barlow or Gabi Gershuny if you would like to find out more.

Written by Gabi Gershuny