EUDR Update 2025: Delay or Not — What It Means for Responsible Sourcing

On 26 November 2025, the European Parliament voted (402 in favor, 250 against, 8 abstentions) to postpone the entry into force of the EU Deforestation‑Free Regulation (EUDR) by one year — while also adopting revisions to soften certain due diligence (DD) obligations.

This decision doesn’t yet make the law final — a new negotiating phase with the Council of the European Union will determine the final text. The updated rules still need to be endorsed and published in the EU Official Journal before they become enforceable. Until then, the new timelines remain non-binding and preparatory.

Reuters+2ESG Today+2

📅 New Deadlines (Proposed)

• Large operators and traders: compliance expected by 30 December 2026.
• Micro and small enterprises: compliance by 30 June 2027, with simplified obligations. EU Today+1

These dates are provisional and depend on final approval of the adjusted regulation.

Key Changes Approved by the European Parliament

• The core due diligence obligation will apply only to businesses that first place products on the EU market — not to all downstream traders. Parlamento Europeo+1
• Micro and small primary producers will only need to submit a one-off simplified declaration, not repeated full due-diligence filings. Parlamento Europeo+1

These amendments aim to reduce administrative burden — particularly on smallholders and small-scale producers — while preserving the fundamental goal of deforestation-free sourcing. Mishcon de Reya LLP+1

🌱 Why the Delay — And What It Reveals

The delay reflects widespread concern among EU Member States, trade partners and supply-chain actors that many parties remain unprepared.
Key reasons include:

• Technical difficulties setting up the required IT system for due-diligence declarations. Latham & Watkins+1
• Complexity of tracing global supply chains — especially for commodities like cocoa, coffee, soy, palm oil, rubber, timber and their derivatives. PwC+1

While the postponement offers breathing room for producers and exporters, experts warn that each delay risks undermining the regulation’s environmental credibility and may encourage further deforestation before enforcement begins. EU Today+2IDOS Research+2

What This Means for NH Superfoods and Our Partners

At NH Superfoods, we have always embraced transparency, traceability, and sustainable sourcing as core values. Even before the EUDR, we implemented rigorous due diligence protocols across our supply chains — especially for sensitive commodities like cacao.

But the evolving timeline and regulatory uncertainty emphasize two important points:

1. Preparation remains essential. Even with the delay, final adoption is expected before end of 2025 — meaning the compliance countdown effectively continues.
2. Certainty matters for investment and trust. Businesses, producers, and exporters require stable, enforceable rules to confidently invest in traceable, deforestation-free supply chains.

We continue to urge regulators to finalize the law promptly and to maintain its original ambition. Meanwhile, NH Superfoods remains fully committed to sourcing practices that respect forests, biodiversity, and the communities behind every ingredient.

A Broader View: EUDR in Context

The EUDR — originally adopted in 2023 — aims to ensure that certain high-risk commodities like cocoa, palm oil, coffee, soy, timber, rubber and cattle (and their derivatives) placed on the EU market are not linked to deforestation or forest degradation. lawcode.eu+2Environment+2

Under upcoming obligations, companies will need to conduct rigorous due diligence, traceability checks, and risk assessments across their supply chains, with annual reporting and geo-referenced data for origin plots. PwC+1

The recent amendments reduce the burden for small actors and downstream traders — but many industry voices caution that weakening enforcement or overly broad exemptions could undermine the core goals of climate change mitigation and biodiversity protection. IDOS Research+2EU Today+2

Final Thoughts

Delays or adjustments may offer short-term relief to supply chains — but the urgency of climate change and forest conservation remains unchanged.

𝐀𝐭 𝐍𝐇𝐒𝐮𝐩𝐞𝐫𝐟𝐨𝐨𝐝𝐬 | 𝐍𝐇𝐂𝐚𝐜𝐚𝐨, we have always adhered to EU regulations and remain fully committed to compliance and sustainability but we urge policymakers to provide clear and stable rules. 𝐁𝐮𝐬𝐢𝐧𝐞𝐬𝐬𝐞𝐬 𝐫𝐞𝐪𝐮𝐢𝐫𝐞 𝐜𝐞𝐫𝐭𝐚𝐢𝐧𝐭𝐲 𝐭𝐨 𝐢𝐧𝐯𝐞𝐬𝐭 𝐜𝐨𝐧𝐟𝐢𝐝𝐞𝐧𝐭𝐥𝐲 and support global efforts to combat deforestation.

We will continue to monitor developments closely, update our protocols accordingly, and work with our partners to ensure that every cacao bean, grain, or superfood ingredient we source respects both people and planet.