2.1 From proposal to application
| Date | Event |
|---|---|
| 17/11/2021 | The Commission presents the proposal for a regulation |
| 31/05/2023 | Regulation (EU) 2023/1115 adopted by the European Parliament and the Council |
| 09/06/2023 | Publication in the Official Journal (OJ L 150, p. 206) |
| 29/06/2023 | Entry into force (20th day after publication). Start of the transition period. All countries are classified as "standard risk" (Article 29(2)) |
| 30/12/2023 | Deadline for Member States to notify their competent authorities (Article 14) |
| 02/10/2024 | The Commission publishes the Strategic Framework for international cooperation, with the principles of the country classification methodology |
| Nov. 2024 | User registration opens in the Information System |
| 04/12/2024 | Launch of the Information System (TRACES) — FAQ 7.9 |
| 19/12/2024 | Regulation (EU) 2024/3234: postpones application by 12 months (to 30/12/2025 and 30/06/2026) |
| 22/05/2025 | Implementing Regulation (EU) 2025/1093: first list of low-risk and high-risk countries |
| 19/12/2025 | Regulation (EU) 2025/2650: a further postponement (30/12/2026 and 30/06/2027) and structural simplifications |
| 26/12/2025 | Consolidated text used in this report |
| H1 2026 | Temporary closure of the Information System to adapt it to the 2025 amendments (FAQ 7.9) |
| Apr. 2026 | FAQ — version 5 |
| 04/05/2026 | Simplification review report COM(2026) 191 — no new legislative proposal |
| Jun. 2026 | The Information System reopens, with functions rolled out in stages over the European summer |
| 13/07/2026 | The Commission adopts a delegated act amending Annex I, and Implementing Regulation (EU) 2026/1565, amending the rules of the Information System |
| 20/07/2026 | Guidance Document C/2026/3896 (3rd edition) published in the Official Journal |
| Aug. 2026 | Supply chain infographics — 5th edition |
| 30/12/2026 | Application begins for large and medium-sized companies. The EUTR is repealed |
| By Dec. 2026 | The Commission intends to launch the repositories of relevant legislation of producing countries and of certification schemes |
| 30/06/2027 | Application begins for micro and small companies established up to 31/12/2024 |
| After 30/12/2027 | Publication of the first annual due diligence reports by non-SME companies (reference year 2027 — FAQ 5.14) |
| 30/12/2027 | Application begins for the products added by the 2026 delegated act (instant coffee, palm derivatives, frozen bovine tongues, palm-based soaps) |
| 31/12/2029 | End of the residual application of the EUTR to timber produced before 29/06/2023 |
| 01/12/2029 | Deadline for the electronic customs interface (Single Window) to be operational (Article 28) |
| 30/06/2030 | First general review of the Regulation (Article 34(2)) and every five years thereafter |
2.2 What changed with Regulation (EU) 2025/2650
The December 2025 package is the most important amendment since adoption. Its main changes:
| Topic | Before | After |
|---|---|---|
| Dates of application | 30/12/2025 (large/medium) and 30/06/2026 (micro/small) | 30/12/2026 and 30/06/2027 |
| Categories of actors | Operator and trader (SME and non-SME) | Operator, micro or small primary operator (MSPO), downstream operator and trader |
| Downstream due diligence | Non-SME downstream operators and traders had their own due diligence and statement duties (and could refer to earlier DDS) | Downstream operators and traders do not carry out due diligence and do not submit a DDS |
| Small producers in low-risk countries | A DDS like any operator | A single simplified statement (Article 4a and Annex III), with the option of a postal address instead of geolocation |
| Downstream DDS references | Reference numbers travelled along the whole chain | The operator passes them only to the first downstream link; later links keep only supplier and customer data |
| Registration in the system | Broader registration rules | Operators (or their authorised representatives) and, downstream, only non-SME operators and traders |
| Printed products (Chapter 49) | Covered | Removed from Annex I |
| Review | The review clauses of the original text | A simplification review by 30/04/2026 (new Article 34(1a)) and a general review by 30/06/2030, with a broader list of topics |
2.3 The 2026 package: report, delegated act and system rules
Report COM(2026) 191 (04/05/2026). The Commission concluded that the simplifications cut annual compliance costs by around 75% — from 8.1 to 2.0 billion euros. It reported that 51% of importing operators now source from low-risk countries, and that the universe of unique importing operators fell from 352 thousand to around 275 thousand with the scope adjustments. It recorded more than 33 thousand participants across 85 online training sessions since October 2024. No new legislative proposal followed.
Delegated act on Annex I (adopted on 13/07/2026). Subject to scrutiny by the European Parliament and the Council, which may veto but not amend it. According to the sources consulted, it removes from scope bovine hides and skins (4101, 4104, 4107), retreaded tyres (except the new tread), conveyor and transmission belts and other articles of vulcanised rubber, non-wooden seats and soybeans for sowing; it adds instant coffee and coffee extracts (2101 11), certain oleochemical palm derivatives and palm-based soaps, and frozen bovine tongues, the latter applying from 30/12/2027. It also creates horizontal exemptions for samples and test materials, packaging, used and second-hand goods, waste, correspondence, and marketing and information materials.
Implementing Regulation (EU) 2026/1565. It amends Implementing Regulation (EU) 2024/3084, which governs the Information System, to accommodate the simplified statement, the new registration roles, the voluntary grouping of reference numbers, automatic risk profiles, API specifications and contingency procedures in the event of downtime.