EUDR deadline 2026: which application date applies to you

The EUDR applies from 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small operators dealing in non-timber products. There is one trap: micro and small operators whose products were already covered by the EU Timber Regulation do not get the later date — they are caught by 30 December 2026 like everyone else.

That split is the single most misread part of the regulation as it now stands, and getting it wrong in the optimistic direction means trading unlawfully for six months.

The dates, as they actually stand

Regulation (EU) 2025/2650 was published on 23 December 2025, following political agreement between the Parliament and Council on 4 December 2025. It postponed application of Regulation (EU) 2023/1115 and simplified several obligations at the same time.

Who you are	Application date
Large and medium operators and traders	30 December 2026
Micro and small operators — products already covered by the EU Timber Regulation	30 December 2026
Micro and small operators — all other products	30 June 2027

The regulation entered into force long ago. What was postponed is the date its obligations bite. Nothing about the postponement reduces what you eventually have to produce.

How company size is decided

Size is not a matter of self-description. It follows the thresholds in Directive 2013/34/EU, as uprated by Delegated Directive (EU) 2023/2775 for financial years beginning on or after 1 January 2024. You fall into a category if you do not exceed two of its three criteria.

Category	Employees	Net turnover	Balance sheet total
Micro	10	€900,000	€450,000
Small	50	€10,000,000	€5,000,000
Medium	250	€50,000,000	€25,000,000
Large	exceeds two of the medium criteria

Two consequences catch people out. A business with 30 staff and €12m turnover is not small — it exceeds turnover and sits in the medium band on that test. And group structures matter: if you are consolidated into a larger group, the group's figures are usually what count.

The Timber Regulation trap

This is the provision that most often moves a business from June 2027 back to December 2026.

If your products fell within the scope of Regulation (EU) No 995/2010 — the EU Timber Regulation — then being micro or small does not buy you the extra six months. Timber, sawn wood, panels, flooring, plywood, pulp, paper and a wide range of wood products were all within EUTR scope.

So a small furniture importer who assumes June 2027 because they employ 25 people is very likely wrong. If they were placing timber products on the EU market under EUTR, their date is 30 December 2026.

The practical test is not "did we comply with EUTR" but "were our products within its scope". A business that should have been meeting EUTR obligations and was not still loses the extension.

What the postponement did not change

The cut-off date did not move. Relevant products must be produced on land not subject to deforestation after 31 December 2020, and wood must not have caused forest degradation after that date. A five-year-old supply relationship does not grandfather anything.

The seven commodities did not change: cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus the derived products in Annex I. Scope is determined by customs (CN) code, which is why so many businesses discover a product line they did not expect — wooden packaging, leather trim and palm derivatives are all caught even where the headline product is not.

Nor did the penalties change: fines with a maximum of at least 4% of annual EU-wide turnover, confiscation of products and of revenues derived from them, exclusion from public procurement and public funding for up to 12 months, and a temporary prohibition on placing products on the market for serious or repeated infringements.

What did change, and in your favour

Regulation (EU) 2025/2650 concentrated the due diligence statement on the operator who first places the product on the EU market. Downstream operators and traders no longer file their own statements; they collect and retain the reference number of the statement filed upstream. Downstream operators and traders that are not SMEs must still register in the Information System.

Micro and small primary operators sourcing only from countries benchmarked low risk get two further concessions: a single simplified declaration rather than a statement per consignment, and postal codes in place of precise geolocation coordinates.

Working backwards from your date

Whichever date applies, the binding constraint is almost never the paperwork. It is getting production-country and plot-level data out of suppliers who have never been asked for it.

Response times run to weeks, and the suppliers least able to answer are precisely the ones you will need to replace — which is a sourcing project, not a compliance one. A business that begins collecting geolocation three months before its date generally does not finish.

Counting backwards from 30 December 2026, a realistic plan starts supplier outreach around July 2026, has registration in the Information System done by September, and files a dry-run due diligence statement on a real consignment by the end of November, while a failure is free.

Confirm which date is yours

The difference between the two dates turns on your size classification and on whether your goods were within EUTR scope — two questions most businesses can answer in a minute, and which are worth answering in writing.

Check which EUDR deadline applies to your business and get a dated plan counted back from it.