STiR coffee and tea magazine

Volume 15, Number 1 / Spring 2026

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10 STiR coffee and tea | 2026 Quarter 1 Spring (Mar/Apr/May) 2019 — Policy Trigger December: The European Green Deal identifies the EU's role in global deforestation as a structural environmental risk requiring regulatory intervention. 2025 — Second Formal Postponement December 23: Regulation (EU) 2025/2650 is published, again amending Article 38. Current legally binding application dates are set to: ● December 30, 2026 — general application for large and medium enterprises ● June 30, 2027 — application for micro and small enterprises The amendment also aligns the repeal of the EU Timber Regulation (EUTR) with the new timeline. 2024 — First Formal Postponement December: The European Parliament and the Council reach a provisional political agreement. December 23: Regulation (EU) 2024/3234 amends Article 38, postponing application to: ● December 30, 2025 — general application for large and medium enterprises ● June 30, 2026 — application for micro and small enterprises 2023 — Legal Adoption June 9: Regulation (EU) 2023/1115 is published in the Official Journal. June 29: The EUDR comes into force. Original application dates set in the 2023 regulation: ● December 30, 2024 — general application for large and medium enterprises ● June 30, 2025 — application for micro and small enterprises 2022 — Political Agreement December 6: The European Parliament and the Council reach a provisional political agreement. The scope is expanded to include coffee and rubber, and forest degradation is added alongside deforestation. 2021 — Legislative Proposal November 17: The Commission presents a proposal for a regulation on deforestation- free products, replacing voluntary approaches with mandatory supply-chain due diligence and geolocation requirements. 2020 — Evidence-Based November: The European Commission publishes The impact of EU consumption on deforestation, establishing the analytical foundation for binding due-diligence legislation. Timeline of the EU Deforestation Regulation (EUDR): From Political Intent to Delayed Enforcement EUDR Delays Elicit Relief and Regret On December 19, 2025, the European Parliament and Commission approved a second one-year pause in the application of the European Union Deforestation Regulation (EUDR). The amend- ment was officially published the day before Christmas Eve, on December 23, as an unintend- ed gift for many companies, countries, producers, and value networks struggling to comply. The new dates for the regulation implementation are: ● December 30, 2026, for large companies, non-SME operators, and traders ● June 30, 2027, for micro and small undertakings The amendment also sets a new due date for the broader evaluation of the regulation. The general review of the EUDR is now scheduled for June 30, 2030, with the main objective of allowing the Commission to assess the regulation based on actual enforcement experience. For many companies and producing countries that have already invested significant resources, are prepared to comply, and oppose this post- ponement, the amendment sets out five main considerations. These considerations include the need to do the following: ● Reassess and adjust the regulation to reduce unnecessary administrative burdens that could affect EU competitiveness; ● Further prepare the EU information system, launched on December 4, 2024, to handle a significantly higher volume of interactions than initially anticipated; ● Simplify procedures and requirements to remove avoidable regulatory burdens; ● Give companies, producing countries, operators, and traders enough time to fully comply with their obligations; and ● Finish technical developments of the system, including its integration with customs interfaces. Beyond delaying implementation, the amendment introduces significant adjustments. These include changes to certain definitions and categories, reductions in reporting and due diligence obligations for specific actors, and additional ways to provide traceability informa- tion. In particular, the amendment creates two new categories, "micro or small primary opera- tor" and "downstream operator," both subject to reduced and more focused reporting require- ments, explicitly designed to limit their interac- tion with the EU information system. All these measures are presented by EU institutions as adjustments adopted while maintain- ing the objectives of the regulation, namely to prevent deforestation-linked products from being placed on or exported from the EU market. Responses to the second postponement and related changes to the EUDR have been mixed. Coverage that supports the postponement EUDR delays alleviate compliance burdens, while others worry that forests are still at risk. emphasizes that lawmakers and some industry associations view the delay as a pragmatic response to implementation challenges. Euronews reported that, in the European Parliament's vote to delay and soften the deforestation regulation, some Members of the European Parliament (MEPs) welcomed the postponement, arguing that it will give "authorities and operators the time needed to implement the rules properly." This reflects a pro-delay position that frames the postponement as a way to reduce unnecessary burdens on farmers, value networks, and businesses while preserving the core objectives of the law. Criticism of the postponement mainly comes from entrepreneurs, environmentalists, and civil society perspectives. The Rainforest Alliance, in a response to the Commission's proposal to delay the EUDR again, stated that it "regrets the agreement" to postpone the regulation and expressed concern that the decision "seriously harms the credibility of the EU" and adds to uncertainty for businesses and producers who had invested in compliance. This reaction reflects concern that repeated postponements risk weakening the regulation's impact and undermining legal certainty. At the same time, companies that invested early in EUDR compliance have expressed frustration, noting that repeated changes to timelines and requirements increase costs and uncertainty, and may disadvantage first movers. For these actors, the amendment also highlights broader questions around regulatory predictability and the stability of EU sustainability policy. For now, aside from the amendment, the EU Parliament and Commis- sion have maintained the main objectives and the spirit of the EUDR and hope that the implementation commitment is underway, which might just be an ethical Christmas gift for future generations. By Emilio Bonnet Coffee Report

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