[Breaking News] EU Commission Stand Firm on EUDR Deadline: No Delay Proposed for Large Enterprises

Executive Summary: 

The EU Commission has reversed the expected EUDR delay, proposing full implementation by December 2025 with (grace period of six months for checks and enforcement) and simplified compliance for small and micro operators. This move reinforces the EU’s commitment to deforestation-free trade while ensuring inclusion. Large and medium enterprises must maintain full compliance, while smallholders gain extended transition periods. Now is the time for agribusinesses to adopt digital traceability systems. Koltiva continues to drive transparency, trust, and sustainable growth across global supply chains. 

Table of Index

1. Introduction: EUDR’s Pivotal Shift Toward Inclusive Compliance 

   • The context of EUDR’s role in transforming global agricultural supply chains 

   • The European Commission’s October 2025 proposal 

   • How Koltiva continues to monitor and interpret regulatory shifts 

2. Key Highlights from the EU Commission's Proposal 

   • No Blanket Delay for Large and Medium Enterprises 

   • Introduction of New Category ‘Downstream Operators’ 

   • Reduced Reporting for Traders and Downstream Operators 

   • New Definition: ‘Micro and Small Primary Operators’ 

   • Simplified Compliance for Micro and Small Primary Operators 

   • Extended Timeline for Small Operators 

   • Grace Period for Enforcement and Penalties 

3. Implications for Agricultural Supply Chains 

   • Overview of how the EUDR affects key commodities: coffee, cocoa, palm oil, and rubber 

   • For Micro and Small Primary Operators 

   • For Non-SME Downstream Operators and Traders 

   • For First-Placing Operators (Importers/Exporters) 

   • Opportunity: leveraging Koltiva’s solutions for readiness and inclusion 

4. Koltiva’s Perspective: Building Readiness Beyond Compliance 

   • A Call for Data-Driven Supply Chains 

   • Empowering Smallholders: Digital inclusion through mapping, training, and mobile tools 

   • Real-World Solutions for Global Enterprises 

   • Beyond Compliance: Creating ethical and resilient supply chains as a long-term advantage 

5. Staying Ahead in the Traceability Race: 5 Action Steps for Businesses Preparing for EUDR 

6. What to Expect Next 

Introduction: EUDR’s Pivotal Shift Toward Inclusive Compliance 

The European Union Deforestation Regulation (EUDR) has been one of the most transformative sustainability laws for global agricultural supply chains. As the compliance date approaches, all eyes are on how the EU will implement this ambitious regulation designed to ensure that products entering the European market are free from deforestation and forest degradation. 

On October 21, 2025, the European Commission issued a proposal containing a series of targeted simplifications to support smoother implementation, particularly for small and micro operators, as well as downstream actors. Contrary to expectations of a broad delay, the Commission reaffirmed that large and medium-sized enterprises must comply by the original deadline of December 30, 2025 (European Commission, 2025). 

However, micro and small operators from low-risk countries will benefit from a one-year delay and simplified due diligence requirements, including a one-off declaration in the EUDR IT system. Downstream actors, such as retailers and manufacturers, will no longer be required to submit separate due diligence statements, streamlining compliance across the supply chain 

For us at Koltiva, this moment reinforces our long-standing belief that technology, traceability, and transparency are essential pillars of sustainable supply chains. The EUDR update signals  that prioritizes inclusivity without compromising environmental integrity. 

Key Highlights from the EU Commission’s Proposal  

The European Commission’s October 21, 2025 proposed a series of targeted adjustments to the EUDR, aiming to strike a balance between environmental ambition and practical implementation. These updates are particularly significant for companies preparing for the December 2025 compliance deadline.  

Here’s what businesses need to know: 

• No Blanket Delay for Large and Medium Enterprises  

  While some anticipated a broader postponement,  the Commission proposal indicates that there will be no general delay of the EUDR for large and medium-sized companies. These operators, especially those sourcing cocoa, coffee, palm oil, rubber, and soy are still expected to meet full compliance requirements, including traceability to the plot level, by December 30, 2025. 

• Introduction of New Category ‘Downstream Operators’ 

  The proposal introduces a new category, “downstream operators,” aimed at clarifying roles and simplifying reporting obligations.  These actors such as retailers and manufacturers are now treated similarly to traders but are exempt from submitting due diligence statements (DDS). However, they must still require to register in the EUDR information system and ensure traceability by passing on reference numbers and declaration identifiers. (5, Page 11).   

• Reduced Reporting for Traders and Downstream Operators 

  Both traders and downstream operators are not required to submit DDS or verify that due diligence was exercised. This change is expected to reduce the volume of interactions with the EUDR information system. Nonetheless, they remain responsible for maintaining traceability by collecting and forwarding relevant documentation from upstream suppliers. (6, page 11). 

  
  

• New Definition: ‘Micro and Small Primary Operators’ 

  A distinct category has been introduced for micro and small primary operators, natural persons or small enterprises based in low-risk countries that produce or export relevant commodities that this operator itself has grown, harvested, obtained from or raised on relevant plots of land, or, as regards cattle, on establishments. These operators are subject to simplified obligations to avoid excluding them from EU markets. (Article 1. 15a) 

  
  

• Simplified Compliance for Micro and Small Primary Operators 

  Instead of submitting full DDS, micro and small primary operators may submit a one-time simplified declaration through the EUDR system. To further ease the burden, geolocation data can be replaced by the postal address of all the plots of where the relevant commodities that the relevant product contains, or has been made using, were produced (Page 16). This approach aims to maintains transparency while supporting inclusivity.  

  
  

• Extended Timeline for Small Operators 

  The application of enforcement measures for micro and small operators are scheduled to December 30, 2026. This gives them an additional year to adapt to the regulation and implement necessary systems. 

  
  

• Grace Period for Enforcement and Penalties 

  For all operators, including traders and downstream actors, enforcement will begin on June 30, 2026, six months after the initial compliance deadline. During this grace period, companies will not face penalties if they can demonstrate genuine efforts to comply. Once enforcement begins, penalties may reach up to 4% of the company’s EU-wide annual turnover, ensuring that non-compliance carries significant financial consequences. (Article 24, Page 21) 

The Commission’s proposal to maintain the original timeline was unlikely to escape debate. Many industry leaders welcomed the regulatory certainty and praised the move as a reward for early adopters. Others appreciated the pragmatic adjustments for smallholders and downstream actors, viewing them as necessary for operational readiness. Despite differing perspectives, one message is clear: EUDR implementation is moving forward. 

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Implications for Agricultural Supply Chains 

The EUDR directly impacts some of the world’s most complex and interconnected agricultural value chains, particularly those of coffee, cocoa, palm oil, and natural rubber. These commodities rely on millions of smallholder producers, involve numerous intermediaries, and operate within diverse national traceability frameworks. 

The European Commission’s October 2025 proposal reinforces that traceability remains central to compliance. All operators must prove that their products originate from land not subject to deforestation after 31 December 2020, verified through geolocation coordinates. Based on the legislative proposal COM(2025)652 final, the updated regulation introduces differentiated implications for various supply chain actors. 

For micro and small primary operators, the update brings welcome relief. These actors are exempt from submitting full Due Diligence Statements (DDS) and instead must provide a one-time simplified declaration, including geolocation or postal address data. Their compliance deadline has been extended to 30 December 2026. This approach significantly reduces administrative burdens, enabling greater participation from smallholders—particularly those in low-risk countries, while still requiring them to maintain traceability and pass on declaration identifiers. 

Non-SME downstream operators and traders, such as retailers and processors, are no longer required to submit DDS or verify due diligence. However, they must register in the EUDR IT system and ensure traceability by passing on reference numbers and declaration identifiers. This adjustment eases compliance workloads while maintaining accountability through transparency and responsiveness to substantiated concerns or enforcement checks. 

Meanwhile, first-placing operators (importers and exporter) remain fully responsible for submitting DDS and ensuring that sourcing is deforestation-free. They must collect geolocation data and verify the legality of production, particularly when sourcing from high-risk regions. These actors face the highest compliance responsibilities but also stand to benefit from regulatory clarity and potential incentives for early compliance. Investments in traceability systems and supplier engagement are now essential for maintaining market access and reputational integrity. 

Ultimately, the EUDR presents both a challenge and an opportunity. By investing in traceability and sustainability, producers can unlock access to premium markets, while businesses strengthen brand credibility and future-proof their operations. With rising demand for digital traceability, geolocation mapping, and compliance reporting tools, platforms like KoltiTrace and KoltiSkills are well-positioned to support readiness and inclusion across the supply chain—ensuring that no actor is left behind in the transition to deforestation-free trade. 

Koltiva’s Perspective: Building Readiness Beyond Compliance 

At Koltiva, we see the EUDR not as a regulatory challenge, but as a catalyst for building stronger, more transparent supply chains. Our experience across more than 94 countries demonstrates that technology and trust must work hand-in-hand to make sustainability real at the ground level. 

A Call for Data-Driven Supply Chains 

The latest EU update signals that data accuracy, interoperability, and traceability are non-negotiable. Koltiva’s integrated ecosystem, from KoltiTrace for digital traceability to KoltiSkills for smallholders capacity building and KoltiPay for financial inclusion, provides end-to-end solutions for EUDR compliance. 

Empowering Smallholders 

Relief measures for small enterprises are a reminder that inclusivity matters. Koltiva helps companies integrate smallholder producers into digital systems through simple mobile tools, field mapping, and digital coaching. By capturing accurate geolocation data, companies can prove deforestation-free sourcing and empower producers with visibility in the global market. 

Real-World Solutions for Global Enterprises 

We are empowering global leaders in cocoa, palm oil, and rubber to demonstrate that early investments in traceability platforms yield tangible benefits—ranging from reduced audit costs and faster verification processes to stronger supplier engagement. As enforcement of the EU Deforestation Regulation (EUDR) approaches, these digital infrastructures are no longer optional, they are becoming essential assets for business resilience and compliance. 

Beyond Compliance 

Sustainability is not just about meeting EU requirements. It’s about creating resilient, ethical, and transparent systems that respect both people and the planet. We help clients turn compliance into a long-term competitive advantage. 

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Staying Ahead in the Traceability Race: 5 Action Steps for Businesses Preparing for EUDR 

While the EU refines its implementation details, companies should stay proactive. Here are five immediate actions businesses can take: 

1. Continue Mapping and Verification

   Ensure all sourcing plots are georeferenced and verified as deforestation-free. Use digital tools to collect and store this data securely. 

2. Clarify Due-Diligence Roles

   Identify who will file declarations in the EUDR Information System; importer, trader, or brand owner,  and formalize these roles contractually. 

3. Digitize Documentation

   Move away from spreadsheets and paper forms. Use integrated platforms like KoltiTrace to automate documentation, evidence tracking, and reporting. 

4. Engage Suppliers and Smallholders

   Support smallholders with training and tools to understand EUDR requirements. KoltiSkills provides customized capacity-building programs to close knowledge gaps. 

5. Stay Informed

   Being proactive now ensures smoother compliance later, even if enforcement flexibility materializes. Participate in European Commission webinars and follow Koltiva LinkedIn and newsletter to stay informed about implementation timelines and best practices. 

   
   

What to Expect Next 

The European Commission’s proposal signals smarter implementation, not less ambition and will now be reviewed by the European Parliament and the Council of the EU. Once approved, it will become legally binding and integrated into the broader EUDR framework. 

Regardless of the political timeline, the fundamental EUDR obligations: due diligence, geolocation mapping, and risk assessment are already set in motion. 

For agribusinesses, the message is clear: there is no turning back on traceability. Building robust data systems, engaging smallholders, and maintaining transparency are now essential to business continuity and market access. 

Businesses that continue to strengthen their traceability systems today will avoid future disruption. Koltiva advises clients to maintain momentum and use this window to refine data quality, supplier verification, and reporting integration.

Partner with Koltiva to accelerate your EUDR compliance journey. 

Koltiva stands ready to guide companies through every step of this journey, from digital farm mapping and due-diligence verification to farmer empowerment and reporting automation. As the EU refines the technical details of implementation, the real opportunity lies in transforming compliance into long-term sustainability leadership. 

Build transparent, resilient, and deforestation-free supply chains with integrated technology, trusted data, and inclusive collaboration. Learn more about Koltiva’s EUDR Solutions. For more insights on EUDR and sustainable sourcing, follow Koltiva's blog and stay updated on our latest innovations and field stories. 

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Author: Gusi Ayu Putri Chandrika Sari, Social Media Practitioner at KOLTIVA

Gusi Ayu Putri Chandrika Sari combines her expertise in digital marketing and social media with a deep commitment to sustainability, supported by over eight years of experience in communications. Her work focuses on crafting impactful narratives that connect technology, agriculture, and environmental responsibility. She is driven by a passion for promoting sustainable practices through compelling, audience-focused content across a variety of digital platforms.

EU Commission proposal COM(2025)652_0_October 2025 .pdf

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