Brussels: The EU Deforestation Regulation is now two months from its first application date, and traders handling cocoa, coffee, palm oil, soya, rubber, cattle and wood are racing to finish their compliance systems. Large and medium operators must apply the rules from 30 December 2026, after the co-legislators agreed a one-year delay in December 2025.

This research note reviews what has changed since that delay, what the Commission’s May 2026 simplification review added, and where operators still face practical uncertainty.

What the EU Deforestation Regulation requires

Regulation (EU) 2023/1115 bans the placement on the EU market of seven commodities, and many derived products, unless they are deforestation-free and legally produced. The cut-off date under the EU Deforestation Regulation is 31 December 2020. Any land cleared for production after that date makes the goods ineligible.

Operators must collect geolocation data for every plot of land and file a due diligence statement through the Commission’s information system. The statement produces a reference number that follows the goods through the supply chain.

How the December 2025 amendments changed the timeline

The Council adopted the revised text on 18 December 2025. Large and medium operators now face the rules at the end of 2026, while micro and small primary operators have until 30 June 2027.

The amendments also lightened the burden for downstream businesses. Only the operator that first places a product on the EU market submits the statement. Retailers and manufacturers further along the chain must keep the reference number but no longer file their own.

Printed products such as books and newspapers were removed from scope, and micro and small primary operators need only a one-off simplified declaration.

What the May 2026 simplification review added

The Commission published its simplification review on 12 May 2026. The package contained a report to Parliament and Council, a draft delegated act clarifying product scope, updated guidance and FAQs, and a revised implementing act on the information system. Public feedback on the draft delegated act closed on 1 June 2026.

For compliance teams, the scope clarification matters most. Customs codes decide which goods the EU Deforestation Regulation covers, and ambiguity at the margins has driven much of the legal advice sought over the past year.

Country benchmarking and the risk of checks

The regulation sorts producing countries into low, standard and high risk. Competent authorities must check 1% of operators sourcing from low-risk countries, 3% from standard-risk countries and 9% from high-risk ones. The first benchmarking list in 2025 placed only four countries in the high-risk category: Belarus, North Korea, Myanmar and Russia.

Most large producers, including Brazil and Indonesia, were rated standard risk under the EU Deforestation Regulation benchmarking. That keeps the inspection burden moderate, but it also means traceability, not geography, is the main compliance hurdle for importers.

What happens next

Three questions will shape the first months of the EU Deforestation Regulation in practice. Will the information system cope with the volume of statements filed at once? Will member state authorities be staffed to run risk-based checks? And will producing countries, from Latin America to Southeast Asia, see the rules as workable or as a trade barrier?

The Commission has signalled that further simplification remains possible. For now, operators should assume that the EU Deforestation Regulation will apply on 30 December 2026 and plan geolocation, supplier mapping and due diligence workflows accordingly.