'We remain on track' – But Brussels Signals a New Delay
In a letter dated 2 October 2025, addressed to Jessika Roswall, European Commissioner for Environment, Water Resilience, and Competitive Circular Economy, companies operating in the cocoa, dairy, rubber, wood, and agri-food sectors urged the Commission to resist any further changes to EUDR’s timeline.
The letter, also sent to cocoaradar.com, asserts that the signatory firms and their value chains, including smallholder farmers, have invested heavily and in good faith to align with the requirements of the regulation.
They argue that the proposed delay:
- threatens the regulation’s core objectives,
- introduces regulatory uncertainty and extra compliance costs,
- sends a negative signal to markets and investors.
They propose instead technical fixes: recognising IT system failures or specific technical challenges as force majeure, granting a short grace period of up to six months (reviewable), and forming a standing technical oversight committee.
As we reported earlier this month, the European Commission publicly confirmed that it intends to delay the enforcement of EUDR again, by one additional year, from December 2025 to December 2026, citing persistent IT infrastructure and capacity issues.
Anthony Myers
More worryingly, Commissioner Roswall has warned that the existing system may not be able to support the expected volume of due diligence filings and risk assessments from operators.
The Commission’s proposed postponement must now be approved by both the European Parliament and the Council of Member States, and a vote is expected later this month.
From Cocoa to Clearing: Liberia’s Loss and a Broader Warning
The letter’s urgency finds added resonance in newly surfaced data from NewsGhana, which reveals that Liberia lost 150,000 hectares of forest cover in 2022 to cocoa cultivation.
Some analysts track this trajectory to cross-border cacao expansion from neighbouring Côte d’Ivoire, overlapping with weak land governance, contested property rights, and permit abuses.
A 2024 IDEF report had earlier flagged this trend: between 2001 and 2022, Liberia lost approximately 2.2 million hectares of forest (roughly 23% of its vegetation cover) — with 150,000 hectares lost in 2022 alone. That same study warned that cocoa from Liberia is often registered under Ivorian entities to skirt export or regulatory constraints.
The concern now is that repeated delays in implementing EUDR weaken deterrents to deforestation in producing countries. The regulation was designed precisely to curb such unsustainable expansions by blocking the import of commodities tied to forest loss after December 31, 2020.
What Comes Next — Stakes, Timelines, and Pressures
If approved, the new delay would force the regulation’s effective date to 30 December 2026.
Until then, CocoaRadar understands that EUDR obligations are currently scheduled to begin for large operators on 30 December 2025 and for micro and small operators in June 2026, unless the legislative change is ratified.
The letter’s signatories are urging the Commission to articulate its next steps promptly so that businesses can plan accordingly. They warn that ambiguity itself is a burden on trade flows, risk management, and investments.
- Check out our complete coverage of the EUDR
Anthony Myers