Has the cut-off date been pushed back too?

No. It is still 31 December 2020. What is delayed is the date from which the Regulation applies.

Does a shipment that leaves origin in December 2026 and arrives in January 2027 need a DDS?

What counts is the date of placing on the market or export, which for an import is release for free circulation. If you clear the goods on or after 30 December 2026 and that date applies to you, you need a DDS even though the goods left earlier.

I am a small company and my customer is a large one. Does that bring my date forward?

Your date for submitting DDSs does not change with the size of your customers. What does happen is that a large customer buying imported products has obligations from 30 December 2026 and may ask you for data to meet them.

Will there be another delay?

The Commission said in May 2026 that it would not reopen the text. As of the date of this guide, no proposal for a new delay has been published.

EUDR deadlines: 2026 and 2027

The EUDR applies from 30 December 2026 to large and medium-sized companies, to all downstream operators and traders, and to micro and small enterprises with wood products that were already under the EUTR. All other micro and small enterprises have until 30 June 2027.

How we got here

Regulation (EU) 2023/1115 entered into force on 29 June 2023 and was due to apply from 30 December 2024. Regulation (EU) 2024/3234 pushed that back one year, to 30 December 2025. Regulation (EU) 2025/2650, published on 23 December 2025, delayed it again and also changed who submits statements.

In its May 2026 report, the Commission said it would not reopen the text of the Regulation and that simplification would continue through delegated acts and improvements to the information system. As of the date of this guide, the dates below are the ones in force.

The dates

30 December 2026: large and medium-sized operators; downstream operators and traders of any size; and micro and small enterprises for the products that were in the EUTR annex (Regulation (EU) 995/2010).
30 June 2027: micro enterprises, small enterprises and natural persons, for all other Annex I products.
30 December 2027: products added to Annex I by Delegated Regulation (EU) 2026/2102, which are soluble coffee, more palm derivatives and frozen cattle tongues.

Products that left the annex (cattle leather and hides, printed products, several vulcanised rubber articles, casings of retreaded tyres) have no date: they are no longer in scope.

The wood exception

Micro and small enterprises get no extension for products that were already under the EUTR. That includes most of Chapter 44, pulp (47), paper and paperboard (48) and wooden furniture under 9403. A small flooring importer in Lugo starts on 30 December 2026, the same as a large company.

Products that were not in the EUTR, such as seats with wooden frames under 9401, follow the general rule: 30 June 2027 for micro and small enterprises. Details on the wood page.

How to tell if you are a micro or small enterprise

The EUDR refers to the categories in Directive 2013/34/EU, which looks at three figures: headcount, balance sheet total and turnover. A micro enterprise has at most 10 employees on average and a small one at most 50, and it also cannot go over the balance sheet or turnover limits set by the directive (what counts is not exceeding two of the three criteria). If you are close to the limit, check with your adviser using the accounts for your last closed financial year.

Note that size only changes the date for those who submit DDSs. Downstream operators and traders all start on 30 December 2026.

If you buy from an importer in the EU

A roaster, a furniture factory or a distributor that buys from EU importers does not submit DDSs, but 30 December 2026 is its date too. From then on it has to collect and keep the reference numbers of the DDSs for what it buys. The practical step is to ask each supplier now to put them on the delivery note or invoice for every delivery, so you do not have to chase them one by one during a check.

If you are not an SME, you have to register in the information system before that date, even if you will never submit a statement.

What to do with the remaining time

As of 2 November 2026 there are eight weeks left until the first date. If your date is 30 December, this order is realistic:

This week: list the CN codes you import and check them against Annex I with the checker.
Weeks 2 and 3: register in TRACES with EU Login and ask for geolocation from the suppliers of the shipments arriving in January.
Weeks 4 to 6: risk assessment for those shipments and a first DDS in the test environment.
Weeks 7 and 8: agree with your customs agent how you will pass on the reference number for the customs declaration (in Spain, the DUA).

If you are a micro or small enterprise and your date is June 2027, use the extra time for what takes longest: getting your suppliers at origin to give you plots with six decimal places.

Frequently asked questions

Has the cut-off date been pushed back too?: No. It is still 31 December 2020. What is delayed is the date from which the Regulation applies.
Does a shipment that leaves origin in December 2026 and arrives in January 2027 need a DDS?: What counts is the date of placing on the market or export, which for an import is release for free circulation. If you clear the goods on or after 30 December 2026 and that date applies to you, you need a DDS even though the goods left earlier.
I am a small company and my customer is a large one. Does that bring my date forward?: Your date for submitting DDSs does not change with the size of your customers. What does happen is that a large customer buying imported products has obligations from 30 December 2026 and may ask you for data to meet them.
Will there be another delay?: The Commission said in May 2026 that it would not reopen the text. As of the date of this guide, no proposal for a new delay has been published.