The European Woodworking Industries express great concern about EUDR

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Christian Morasso
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The European Woodworking Industries are greatly concerned regarding information disclosed

about the EU Deforestation-Free Products Regulation (EUDR)1 in a recent article in the Financial

Times (8th March 2024). According to the article, the EU intends to delay the application of the

much-needed risk-based approach – practically implemented via a risk benchmarking of

producing countries (low, standard, and high risk) – which is essential for enabling compliance

with the EUDR by market actors (operators, traders, importers, exporters, and their authorised

representatives) and the competent authorities of the EU Member States (CAs), as well as for

incentivising good practices in producing countries (EU Member States or third countries).

Instead, all countries will now apparently be designated as “standard risk” in order to “give them

more time to adapt” to the new Regulation. It is crucial to understand that the benchmarking of

countries is a central part of the EUDR and its implementation, and any delays related to this

classification will only result in additional costs and administrative burden for market actors,

without any real advantages either for the producing countries or for the CAs.

Indeed, per the EUDR, whether market actors source their commodities from standard risk

countries or from high-risk countries, they are facing the same due diligence obligations. Simply

put, the benefit implied by the seemingly planned delay of the country risk benchmarking does

not exist because no simplified procedure for export or imports is actually foreseen for standard

risk countries, compared to high risk countries.

The only difference between the two tiers of risk is the implication that it has on the control and

verification obligations of CAs: CAs must control 9% of all the operators placing or making

available on the market or exporting relevant commodities and products originating from high risk

countries, compared to 3% in the case of relevant commodities and products originating from

standard risks countries (as per Article 16, paragraphs 8 and 9 of the EUDR).

However, it is essential to identify low-risk countries as the implications are significant to all the

actors: when sourcing from low-risk countries, market actors do actually benefit from the

possibility of simplified due diligence, while CAs can reduce the number of controls to 1%, as

foreseen by Article 16 paragraph 10.

The difficulties associated with the implementation of the EUDR are also reflected by the

challenges faced by the EU when seeking to deliver on its own commitments under the

Regulation.

(Link: Regulation (EU) 2023/1115)

One such example is the task of benchmarking the risk level of countries, particularly

the identification of the low risk-countries, which, to underline again, needs to take place

urgently.

An aggravating factor is that the EU’s Information System, intended to be the main tool supporting

the EUDR implementation by all the actors, is still at an early stage of development and needs

significant improvement, in particular when it comes to the automatic, reliable and safe

collection, registration, and protection of commercially sensitive information . Moreover, in the

case of timber, aspects related to the transition period from the currently applicable EU Timber

Regulation (EUTR)3 to the EUDR still need to be clarified. The goal is to ensure that wood which

has been legally sourced until 30 December 2024 in full compliance with the EUTR can be sold

on the EU market. It is crucial that the EU Information System takes this into account and does

not require retrospective submission of Annex2 data of downstream producers when they place

goods (e.g., sawn wood) on the markets which originates of raw material harvested before 30

December 2024.

 

Conclusion:

The European Woodworking Industries fully support the scope and the objectives of the EUDR

and strongly oppose all forms of deforestation and forest degradation. At the same time, the

European Woodworking Industries regret that the EUDR has become a huge administrative and

regulatory monster.

In the light of all the above, the European Woodworking Industries urge the EU institutions to delay

the entry into application of the EUDR for the operators and traders , to amend the EUDR in order

to eliminate unnecessary bureaucratic hurdles and to provide actors with sufficient time to adapt

for full and adequate compliance.

Moreover, it is imperative that the EU Commission swiftly proceed with the classification of the

low risk countries, with this action being its main priority.

 

Signatories:

CEI-Bois – The European Confederation of Woodworking Industries –

Transparency register n° 470333818389-37

EFIC: European Furniture Industries Confederation –

Transparency Register n° 95910795422-52

EOS - European Organisation of the Sawmill industry –

Transparency register n° 024776016336-52

EPF- European Panel Federation –

Transparency register n°: 572064811767-22

ETTF - European Timber Trade Federation –

Transparency register n° 151485550468-20

FEP- European Federation of the Parquet industry –

Transparency Register n° 294492727880-53

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