The European timber industry’s concerns about the EUDR: a call for clarity

ProPopulus Team

The European timber industries, of which the poplar chain is a major part, are increasingly concerned about the implementation of the European Union’s Regulation against Deforestation and Forest Degradation (EUDR).

In a document published on 12 March, the European timber industries expressed their concerns. The document’s signatories include EOS (European Sawmill Industry Organisation), EPF (European Federation of Wood-based Panels), CEI-Bois (European Confederation of the Woodworking Industries), EFIC (European Furniture Industries Confederation), ETTF (European Timber Trade Federation) and FEP (European Federation of the Parquet Industry).

The document cites recent revelations, reported in the Financial Times on 8 March 2024, which are giving rise to serious concerns, and which relate in particular to the European Commission’s intention to delay the development of one of the key tools of the regulation, the mapping of risk areas at global level.

Risk-based country classification and its implications

The risk-based approach is at the heart of the EUDR Regulation. It consists of classifying countries or production zones according to 3 risk categories: low, standard or high. This classification is essential both for compliance with the regulation and for its application by the various market players and the competent authorities in the EU Member States.

However, to compensate for the absence of this risk mapping, it seems that the Commission intends to classify all countries as ‘standard risk’, which poses major problems.

Under the EURD regulation, market players are subject to similar due diligence obligations, whether the source country of their supplies is classified as standard risk or high risk. However, due diligence obligations may be reduced for market players when the country from which they source their timber is classified as low risk.

Furthermore, the distinction between low risk, standard risk and high-risk countries affects the control and verification obligations of the competent authorities of the Member States.

Consequently, any delay in the comparative assessment of risks by country only increases the administrative burden without offering any tangible benefits. In this context, the identification of low-risk countries is essential, as it optimises the burden of due diligence procedures for market players and reduces the burden of control procedures for the competent authorities.

The timber industries are therefore calling for the process of identifying risk levels and classifying countries according to these levels to be completed rapidly, and for this task to remain at the heart of the European Commission’s priorities.

Other challenges linked to the implementation of the EURD

The implementation of the EURD also relies on another central tool: the Information System on which market players will have to enter their due diligence declarations before placing their products on the market or exporting them. This Information System, developed by the European Commission, has undergone an initial full-scale evaluation.

In the document published, the European woodworking industries criticise the fact that it is too underdeveloped and call for it to be substantially modified and adapted, in particular for automated, reliable and secure collection, recording and protection, given the sensitivity and complexity of the information that will have to be declared.

In addition, the European timber industries are awaiting a number of clarifications, for example concerning the procedures and transition periods between the EU Timber Regulation (EUTR) currently in force and the future EUDR. Questions include whether the Information System developed for the application of the EUDR will recognize, during the transition period, timber that complies with the EUTR when it is placed on the market.

While the European timber industries fully support the objectives of the EUDR in combating deforestation and forest degradation, they stress the need to address the administrative complexities of the regulation. They also urge the European Commission to delay the application of the Regulation for operators and traders, and call for amendments to the text to streamline bureaucratic processes and provide sufficient adaptation time for market players.

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