According to the latest proposals from the European Commission, the obligations under the EUDR are to cover large and medium-sized enterprises from December 30, 2025, while micro and small companies from June 30, 2026. A six-month transition period is foreseen for larger entities, during which no penalties will be applied, but the actual commencement of due diligence rules will be required.
This means that there is significantly less time for preparation than initially anticipated. Companies will also be obliged to implement due diligence procedures, i.e., collecting and reporting detailed data on the origin of goods, including geolocation coordinates of production sites, raw material production dates, and information on suppliers. This data will be entered into the EU’s electronic EUDR system, which will allow for declarations of compliance to be submitted even before goods are introduced into the EU market.
A change for thousands of entities
It is estimated that in Poland, the new regulations will cover even 120 thousand companies – importers, exporters, and manufacturers operating within the EU market. Each of them will be required to assess risk and submit an electronic due diligence declaration, and non-compliance with the regulations may result in severe penalties. Moreover, even intra-EU trade, such as the sale of window solutions from Poland to other member countries, will be subject to the EUDR reporting obligation.
For entrepreneurs, this means the need for digitalization of trade documentation, accurate identification of suppliers, and verification of their compliance with the regulation’s requirements. If a particular trading partner cannot provide the required data, in many cases the only solution will be to change the supplier. This is challenging but necessary because responsibility for EUDR compliance lies with every entity participating in the supply chain.
New standards
The EUDR regulation requires companies not only to collect data on the origin of goods but also to create risk management and supplier audit procedures. In practice, this means a deep transformation of procurement, logistics, and compliance processes. Organizations that start analyzing their supply chains now, implement risk assessment tools, and integrate due diligence procedures with customs systems will be much better prepared for the regulation’s entry into force.
EUDR also introduces new realities for international partners. In many countries outside the EU, such as Ghana, systems for tracking products (e.g., cocoa) from the plantation to the export port are already being developed to enable European importers to meet the new requirements. This shows that EUDR is becoming not only an EU but also a global standard for sustainable raw material trade. This presents a challenge for logistics companies, importers, and manufacturers, but it is also an opportunity to strengthen competitive position.
