After two postponements, the EUDR application dates are fixed: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small enterprises. That is 154 and 336 days from today. This guide explains where those dates come from, how to determine - precisely, not by feel - which one applies to you, and what has to exist inside your company by the day it does.
How we got here
Regulation (EU) 2023/1115 entered into force on 29 June 2023 with application set for 30 December 2024. In late 2024 the EU postponed application by twelve months, citing readiness of operators and the IT systems; a second postponement followed, landing on the current dates. Treat them as final: the political appetite for a third delay is spent. Enforcement infrastructure - TRACES registration, the country benchmarking list, competent authorities in each member state - is already operating.
The two dates
| Date | Who | What starts |
|---|---|---|
| 30 Dec 2026 | Large and medium operators and traders | No placing on the market, making available, or export of in-scope products without due diligence and a filed DDS |
| 30 Jun 2027 | Micro and small enterprises (established by 31 Dec 2024) | Same obligations, six months later |
Which category is your company in?
The size test uses the EU Accounting Directive (2013/34/EU), judged on your balance sheet date. You are in a category if you do not exceed at least two of its three ceilings:
| Category | Balance sheet total | Net turnover | Avg. employees |
|---|---|---|---|
| Micro | ≤ €450k | ≤ €900k | ≤ 10 |
| Small | ≤ €7.5m | ≤ €15m | ≤ 50 |
| Medium | ≤ €25m | ≤ €50m | ≤ 250 |
Three traps. First, the later date belongs only to micro and small - a medium company files from December 2026 with the large ones. Second, the SME extension applies to companies established by 31 December 2024; a business founded later does not get the extra six months. Third, if you are near a threshold, have your accountant make the determination in writing - six months of runway is worth an afternoon of their time, and the classification also affects downstream obligations.
Your deadline is earlier than your deadline
The statutory date is when enforcement starts, not when work starts. Walk backwards from 30 December 2026:
- Customs reality: goods arriving in early January 2027 need a DDS reference number at declaration - meaning due diligence completed while the goods were on the water, on data collected before they shipped. For a 4–6 week sea freight lane, your supply chain must be producing compliant data by October–November 2026.
- Supplier lead time: collecting plot geolocation from origin takes one season of nagging, not one email. Contracts signed now for 2026–27 harvests should already contain plot-data clauses - the geolocation guide specifies what to ask for.
- Remediation time: screening will flag some plots. Each flag is a supplier conversation, a boundary correction, or a sourcing change. Budget weeks per iteration, not days.
- System access: EU Login and TRACES operator registration is straightforward but not instant; do it months early and run a test filing against the field list.
Different position, different clock
- Importers (operators): full timeline above applies to you.
- Downstream SMEs buying goods already placed on the EU market: your duty is lighter - keep upstream DDS references - but it starts the same day, and your suppliers' failures become your supply disruptions. Verify their readiness now.
- Exporters: a DDS is needed for goods leaving the EU too; if you both import and export, the earlier obligations dominate your planning.
- Traders: record-keeping duties (who supplied, who bought) begin on the same dates.
Goods already produced: the transitional rules
Two transitional carve-outs matter for inventory planning. Products produced before the regulation entered into force on 29 June 2023 are outside EUDR when placed on the market - useful for slow-moving stock, but you must be able to evidence the production date. Timber is the exception: wood harvested before entry into force remains governed by the old EUTR regime for a transitional period rather than escaping regulation entirely. Neither carve-out helps with anything produced since mid-2023, which by the application dates is nearly everything commercially relevant - so treat the transitionals as an edge case for specific lots, not a strategy. Date evidence (harvest records, production certificates, bills of lading) goes in the same five-year file as everything else.
What non-compliance costs
Member states must provide penalties including fines of at least up to 4% of Union-wide annual turnover, confiscation of the products and of revenues from them, and exclusion from public procurement; the penalties guide itemises the full Article 25 arsenal. Goods without a valid DDS simply do not clear customs - for an SME importer the operational stop is the real penalty, and it arrives with the first non-compliant shipment. If you qualify as micro or small, the SME relief guide covers what the later date does and does not buy you.
The minimum viable readiness list
- Written size classification (which date is yours).
- Product inventory mapped to Annex I HS codes - start from your commodity guide: coffee, cocoa, timber, rubber, soy, palm oil, cattle and leather.
- Plot geolocation flowing from every upstream supplier, validated and screened.
- TRACES access plus one successful test DDS (the filing walkthrough takes you through it).
- A named owner for the five-year evidence file.
Our free gap-analysis checklist turns this into a one-page audit you can run in a morning.
EUDR deadline questions, answered
What is the official EUDR application date?
The application dates are 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small enterprises established by 31 December 2024. Those are the days the obligations start. Entry into force of the regulation happened much earlier, on 29 June 2023, and confusing the two is why some suppliers already believe they are late.
Has the EUDR been delayed again?
No. Two postponements have been adopted and the second one produced the dates above. Nothing further has been agreed, and the enforcement machinery is already running: TRACES accepts operator registrations today, the country benchmarking list is published, and member states have named their competent authorities. Plan against the current dates and treat any further delay as a windfall rather than a schedule.
When does the deadline actually bite for goods in transit?
Earlier than the date itself. Customs wants a DDS reference number at the moment of declaration, so a container landing in early January 2027 needs its due diligence finished before it ever sailed. Subtract your lane time from the application date and that, not the statutory day, is when your data has to be ready.
Does the June 2027 date apply to my company?
Only if you are micro or small against the Accounting Directive thresholds in the table above, and only if the company was established by 31 December 2024. Medium companies file on the December 2026 date alongside the large ones, which is the most common misreading of the two dates and the most expensive one to discover late.