Thought Leadership

Real progress on deforestation starts at the first-mile, not at the deadline.

22 January 2026

Dense forest degradation generates an exposure to risk

The end of 2025 brought even more uncertainty for the EU Deforestation Regulation (EUDR). After months of speculation, the European Commission, Parliament, and Council formally agreed to a set of amendments and a one-year delay, now confirmed through publication in the Official Journal of the European Union.

In practical terms, the compliance timeline has shifted. Large and medium companies now face a December 2026 deadline, while small and micro companies have until June 2027. Some obligations have been narrowed: micro and small primary operators will submit a one-time simplified declaration; due diligence requirements apply only to the first to place on the EU market; printed products have been removed from scope; and the Commission has committed to proposing further simplifications by April 2026.

While these updates bring additional time for companies to prepare, it also brings continued uncertainty of what the final requirements under EUDR will be. Even in the face of delays and uncertainty, it would be a mistake to interpret this as a signal to pause work on deforestation risk.

The real-world cost of deforestation

Globally, deforestation continues at scale. An estimated 10 million hectares of forest are lost each year. Beyond devastating biodiversity loss, forests also play a critical role in regulating the global climate. Deforestation and other land-use changes account for around 11% of global greenhouse gas emissions, making them a significant contributor to climate change according to the UNEP.

Forest loss also undermines water systems, soil health, and local livelihoods, increasing long-term supply chain instability. These impacts do not pause when regulations are delayed.

Why first-mile visibility matters

One of the greatest challenges in addressing deforestation risk is limited visibility into the first-mile of the supply chain, the point where commodities originate at the farm, plot, or production unit level.

Without this visibility, companies may unknowingly source from areas linked to deforestation, even when upstream suppliers appear compliant on paper. Aggregation, indirect sourcing, and fragmented data can obscure land-use change, leaving risk hidden until it surfaces through regulatory scrutiny, investigations, or market pressure.

Improving first-mile insight enables companies to:

  • Identify where deforestation risk is most concentrated
  • Distinguish between low- and high-risk sourcing regions
  • Engage suppliers proactively rather than reactively
  • Build defensible evidence to support future due diligence requirements

In this context, supply chain transparency is not just a compliance exercise - it is a risk management imperative.

Regulatory delays don’t reduce deforestation risk

The underlying drivers of the EUDR remain unchanged. Agricultural expansion, land-use change, and opaque supply chains continue to pose environmental, financial, and reputational risks. While regulatory timelines may shift, exposure to deforestation does not.

One of the clearest signals from the December amendments is that the EUDR framework is still evolving. Further simplifications are expected, but core expectations around traceability, risk assessment, and accountability remain intact.

Looking ahead beyond the EUDR deadline

The EUDR delay offers time - but time is most valuable when it’s used strategically. Companies that invest now in supply chain insight, data quality, and first-mile visibility will be better positioned to adapt as regulatory expectations continue to take shape.

As 2026 begins, clarity may still be uneven, but the direction of travel is not. Understanding supply chains remains one of the most effective tools we have to combat deforestation - regardless of regulatory timelines.