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In brief

On 23 September 2025, the EU Environment Commissioner notified the European Parliament’s Environment Committee chair and the Danish Presidency of her intention to delay the application of the EU Deforestation Regulation (EUDR) by one year.


Key takeaways

The EUDR is intended to ensure that specified products placed on or exported from the EU market do not contribute to deforestation or forest degradation worldwide. Following a previous one-year postponement, the compliance deadline is currently set for 30 December 2025.

However, in light of ongoing IT-related challenges, the EU Environment Commissioner is considering a further deferral of the regulation’s entry into application, potentially extending the compliance deadline to 30 December 2026. We understand that this additional extension is being justified by the need to mitigate uncertainty for competent authorities and operational difficulties for stakeholders both within the EU and in third countries, as well as to allow sufficient time to address the identified risks in the IT system architecture and its ability to perform under the projected operational load when the EUDR commences.

Next steps

We expect further discussions to be held between the Commission, the Parliament and the Council before the delay is formally announced.

For more information, please contact our team of experts.

Author

Eva-Maria is a partner in our Austrian corporate / M&A group and a member of our global sustainability practice. She acts as global lead sustainability partner for our financial institutions industry group, heads Baker McKenzie's capital markets practice in Austria and is a member of our EMEA steering committee for capital markets. Eva-Maria is a dual-qualified lawyer, admitted to practice in Austria and New York. Prior to joining Baker McKenzie's Vienna office in 2008, Eva-Maria worked in the New York, Paris and Frankfurt offices of a well-known US law firm.

Author

Graham Stuart is a partner in Baker McKenzie's London office specialising in product regulation and environmental, health and safety law.

Author

Gabrielle is a Senior Associate in the London office with over 15 years of experience (in the UK, EU and Brazil) supporting global businesses and non-profit organisations with legal, strategy, disputes, risk management and governance advice, in particular for tax and ESG matters.