With less than 100 days available and without clear implementation tools, major European producers and various industries are calling for a delay in the entry into force of the Eudr, the EU Deforestation Regulation which prohibits the placing on the EU market and export of products that have caused deforestation or forest degradation after 31 December 2020 or that are found to be in non-compliance with the legislation of the countries of origin. This is reiterated by Copa Cogeca, the European farmers' organisation, stating in a press release that a number of organisations (listed at the end of the press release) which fall within the scope of Eudr, "fully support the objective of eliminating deforestation and forest degradation" but, in fact, they are calling for a delay in the new regulation’s entry into force. An appeal launched a few days ago by the Italian government, which has made the request to postpone the application of the EU Regulation for at least one year.

"We recognise the importance of global forests in combating climate change, preserving biodiversity and ensuring sustainable raw materials and supply chains, as well as our responsibility to preserve them. However, less than 100 days after the entry into force of the obligations for operators, traders and competent authorities, we are still faced with serious legal and market uncertainties".

"For months -continues the note- operators and traders expressed concerns about the practical feasibility of Eudr and asked the European Commission and Member States to provide the necessary clarifications both on general requirements of the regulation and on product-specific issues. All supply chain actors need clarity to adapt their practices in accordance with the Eudr but this adaptation cannot be achieved at the last minute". 

Time has expired

"It is clear -say from Copa Cogeca- that the time for adequate preparation has long expired and our industries are being asked to implement obligations more quickly than any other industry which has ever been faced with Community legislation similar. The time for adequate preparation for implementation is over. Despite our efforts to prepare for the implementation of the Eudr and repeated warnings over the past year, there are still no adequate answers to our requests for clarity for a feasible and harmonised implementation of the regulation". 

"Our concerns, writes the European farmers' organisation, have not been answered: from the need for a functioning and user-friendly EU information system to the availability of benchmarking, especially for low risk countries. In addition, seven Member States have not yet designated a competent authority for national implementation. The current situation clearly shows that implementing Eudr by the end of 2024 is simply unfeasible and would result in the elimination of many small businesses from the market and loss of jobs in rural areas". 

"Companies are already facing crippling uncertainties in negotiating contracts for next year -the note continues-. As a result, serious market 'disruptions' can be expected that would seriously harm European primary producers and downstream industries. This would threaten the security of the supply chain and reduce market access for food, feed and forest products vital to the EU, as well as the livelihood of rural areas by exacerbating inflationary pressures on consumer goods".

Delay entry into force

"In short -the note goes on- speeding up implementation would entail a high risk of serious negative economic consequences. It is essential that the European Commission and the Member States recognise that the time frame is simply not achievable. Therefore, we ask for immediate action to delay the entry into force of the EUDR and that all necessary compliance tools be provided with the time needed to prepare properly". 

The context

"In April 2024 -says the Copa Cogeca- EU agriculture ministers launched a strong appeal on the urgent need to address simplification and disproportionate administrative burden revealed in the national implementation process. This was supported by the Commissioner for Agriculture who proposed not only to consider the postponement of the/and date/and application of the Eudr but also to quickly examine simplification measures. This request was also supported by several MEPs: since then, the urgency of simplification has become even more evident after the results of the European elections and the declared objective of a high political level (in the EU and in the Member States) To reduce the EU’s bureaucracy".

"On 12 September 2024, in an interview with the Financial Times - adds the note- WTO Director Ngozi Okonjo-Iweala called on the European Commission to radically rethink Europe. Therefore, once postponed, the provision of solutions necessary to carry out the implementation of the regulation should be an absolute priority, while maintaining the objective of banning deforestation-related products from the EU market. While we remain committed to working together to find effective solutions for the Euro, we urge the European Commission and Member States to recognise the seriousness of our concerns and take a decision as soon as possible to delay the entry into force of the directive", concludes the Copa Cogeca.

Signatories:

1. ACE - Alliance for Beverage Cartons and the Environment
2. CCB - Cepi ContainerBoard
3. CEI-Bois - European Confederation of Wood Industries
4. CEPF - Confederation of European Forest Owners
5. CEPI - Confederation of European Paper Industries
6. CITPA - International Confederation of Paper and Board Processors in Europe
7. COCERAL - European Association for the Trade in Cereals, Oilseeds, Rice, Legumes, Olive Oil, Oils and Fats, Animal Feed and Agri-supplies
8. Copa-Cogeca - European farmers and agricultural cooperatives
9. ECMA - European Association of Carton Board Manufacturers
10. EDANA - Nonwovens industry
11. EFIC - European Confederation of Furniture Industries
12. EMMA - European Association of Media Magazines
13. ENPA - European Association of Newspaper Publishers
14. ELO - European Land Owners' Organisation
15. EOS - European Sawmill Industry Organisation
16. EPF - European Federation of Panels
17. ETTF - European Timber Trade Federation
18. ETS - European Tissue Symposium
19. EUSTAFOR - European Association of State Forests
20. FEFAC - European Federation of Feed Producers
21. FEFCO - European Federation of Corrugated Board Producers
22. FEP - European Federation of Parquet
23. EFF - Federation of European Publishers
24. FEFPEB - European Federation of Pallet and Wood Packaging Manufacturers
25. INTERGRAF - European Federation of Press and Digital Communication
26. NME - News Media Europe
27. PRO Carton - European Association of Cardboard and Board Manufacturers
28. UECBV - European Union of Livestock and Meat Trade