Key dates and timeline
Two postponements, one simplification. The current application dates (after Reg. (EU) 2025/2650, Dec 2025) are 30 December 2026 for medium and large operators and 30 June 2027 for operators that are natural persons or micro or small undertakings established by 31 December 2024 (Art. 38(3)) — but not for the products the EUTR already covered, which stay at 30 December 2026 for everyone. Medium-sized companies are SMEs but take the December 2026 date.
Timeline
| Date | Event | Source |
|---|---|---|
| 9 June 2023 | Reg. (EU) 2023/1115 published in OJ. | EUR-Lex 32023R1115 |
| 29 June 2023 | Entered into force (twentieth day after OJ publication). | Art. 38 (original). |
| 30 Dec 2024 | Original application date. Reg. (EU) 2024/3234 postponed it by one year. | EUR-Lex 32024R3234 |
| 30 Dec 2025 | First postponed application date (medium and large operators), per 2024/3234. Superseded. | |
| 30 June 2026 | First postponed application date (micro and small operators), per 2024/3234. Superseded. | |
| 23 Dec 2025 | Reg. (EU) 2025/2650 published. Second postponement + simplification. | EUR-Lex 32025R2650 |
| 26 Dec 2025 | Reg. (EU) 2025/2650 entered into force. | |
| 30 Dec 2026 | Current application date — medium and large operators. | Reg. 2025/2650 amending Art. 38. |
| 30 June 2027 | Current application date — natural persons, micro and small operators established by 31 Dec 2024, except for products on the EUTR Annex, which stay at 30 Dec 2026. | Reg. 2025/2650 amending Art. 38(3). |
| ≥ 30 June 2028 | First Commission review of the country benchmark (at least every 5 years thereafter). | Art. 29(3). |
What Reg. (EU) 2025/2650 did beyond the date shift
- Deleted Annex II point 4 (the standalone field for upstream-DDS reference numbers). The duty to collect those references moved to Art. 5(3)(a), and to keep them five years to Art. 5(4); the old Article 4 paragraphs 8 and 9 no longer exist.
- Downstream operators no longer file a DDS. They collect upstream reference numbers and comply by traceability + notification.
- Non-SME traders no longer file a DDS. Same as downstream operators.
- Simplified registration / notification obligations for downstream parties.
The DDS-filing obligation now applies to the first-place-on-market operator (and SME operators retaining their own filings).
Reading the dates
If you are a medium or large operator placing a commodity on the EU market for the first time, your enforceable date is 30 December 2026.
If you are a natural person, or a micro or small operator established by 31 December 2024, your enforceable date is 30 June 2027 — except for the products the EUTR already covered. Article 38(3), as replaced by Reg. (EU) 2025/2650, opens with "Except as regards the products covered by the Annex to Regulation (EU) No 995/2010": for timber and timber products on that Annex, a micro or small operator's date is 30 December 2026, the same as everyone else's. A medium-sized operator's date is 30 December 2026.
If you are a trader or a downstream operator, post-2025/2650 you have no DDS-filing duty, but you still owe traceability and (for non-SMEs) registration / notification compliance from the dates above.
See also
This page last changed on . It describes the Regulation as it stood then; where a date or a code matters to a decision, check it against the EUR-Lex text it cites.