Industry Calls for Regulatory Clarity and Reduced Burden in EU Deforestation Regulation

In a  joint statement, the associations criticize the Commission’s approach of first indicating postponement, then changing course and abruptly revising the EUDR without adequate preparation time for companies, which has led to regulatory uncertainty and undermined trust in the legislative process.

“The Commission’s proposal to clarify the distinction between first and downstream operators and to remove due diligence and reporting obligations for downstream operators in the EU information system is welcomed. However, the continued requirement for downstream operators to collect and forward reference numbers does not deliver meaningful traceability, but instead results in excessive administrative burden, significant costs, and risks creating an unmanageable number of reference numbers throughout the supply chain”, says Viveka Beckeman, Director General of Swedish Forest Industries Federation.

Industry representatives highlight that existing EUDR implementation systems, developed at considerable expense, are not equipped to handle such data volumes. Internal registers of suppliers and customers should be maintained as a more efficient and less burdensome method to ensure supply chain transparency.

The statement calls for the removal of the reference number requirement. The associations also stress ongoing uncertainties regarding downstream operators’ responsibilities in the event of product bans, non-compliance, or substantiated concerns, and call for the removal of due diligence obligations for downstream operators in these cases.

To address these issues, the industries propose specific amendments, targeting the obligations related to communication of reference numbers and due diligence requirements in cases of substantiated concerns, emphasizing that these changes are necessary to ensure that the EUDR is workable, proportionate, and does not hinder industrial operations. These essential amendments to the Commission’s proposal provide several benefits: genuine regulatory simplification and legal clarity, the ability for companies to build on existing implementation efforts and reduced pressure on the Commission’s IT system - all while upholding the purpose of EUDR, ensuring only compliant products gain access to the EU market.