Brussels – Eighteen EU countries, including Italy, are asking Brussels for further simplification of the EU regulation on deforestation (EUDR). The ministers of Austria, Bulgaria, Croatia, Czech Republic, Estonia, Finland, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Poland, Portugal, Romania, Slovakia, Slovenia, and Sweden wrote a letter to the European Commission and the Commissioners for the Environment, Jessika Roswall and Agriculture Commissioner Christophe Hansen, pointing out that although the law is “a milestone in global forest protection”, it “does not take sufficient account of countries with effective forest protection laws and negligible risk of deforestation“. With the consequence that “the obligations imposed on farmers, forest owners, and operators remain onerous and unjustified for countries with negligible deforestation risk” and “are disproportionate to the objective of the regulation, which is to prevent deforestation where it occurs.” Therefore, “we urge the European Commission to rapidly include the Deforestation Regulation in its simplification plans in order to ensure a coordinated and effective implementation” of the regulation across the Union. In the meantime, “it may be appropriate to further postpone the date of application of the regulation,” the ministers write.
Coming into force on 29 June 2023, the Deforestation-Free Products Regulation (EUDR) seeks to address the main driver of deforestation, i.e. the expansion of agricultural land linked to the production of commodities such as livestock, wood, cocoa, soya, palm oil, coffee, rubber, and some of their derivative products, such as leather, chocolate, tyres, or furniture. Thus, according to the regulation, any operator or trader placing these products on the EU market, or exporting from it, must be able to prove that the products do not originate from land that has recently been deforested or has contributed to forest degradation. Initially intended to enter into force on 30 December 2024, in December last year the EU granted an additional 12-month phase-in period, making the law applicable on 30 December 2025 for large and medium-sized enterprises and on 30 June 2026 for micro and small enterprises, in order to give stakeholders more time to align with the requirements.
In the letter, it is emphasised that “sustainable forest management is key to developing climate resilient forests, ensuring species diversity and enhancing the bio-economy with multiple products and services.” And that, “thanks to the tireless work of the member states, the area covered by forests and wooded areas in Europe has increased in recent decades”. Moreover, for the 18 ministers, “the Regulation constitutes a milestone in global forest protection, providing a solid legal basis for EU action against deforestation, while strengthening international cooperation and including support measures for small producers in third countries”. However, “in its current form”, the text “does not take sufficient account of countries with effective forest protection laws and a negligible risk of deforestation.” And “instead of focusing on deforestation where the risk is highest, the regulation imposes disproportionate bureaucratic obligations on countries where deforestation is demonstrably insignificant.”
After having outlined this framework, the signatories recall that the Commission has placed competitiveness “at the heart of its general and economic agenda” and is “committed to ensuring that European businesses can thrive in the global marketplace and guarantee sustainable prosperity for all EU citizens.” Elements that clash, according to the ministers, with the regulation. So much so that, the ministers note, “given the considerable complexity” of the regulation’s provisions and to allow all parties (farmers, forest owners, operators, competent authorities) to fulfil their obligations, the Commission proposed last year to postpone the regulation’s application date to 30 December 2025. A proposal that was accepted and adopted by the co-legislators in December, along with a Commission statement “affirming its commitment to reducing burdens on businesses by removing unnecessary administrative obligations.”
Ministers acknowledge that “guidelines for simplifying and reducing administrative burdens were adopted by the European Commission in April 2025. However, the obligations imposed on farmers, forest owners, and operators remain burdensome and unjustified for countries with negligible deforestation risk. They are disproportionate to the objective of the regulation, which is to prevent deforestation where it occurs,” they write.
Another issue raised in the letter is that of costs, because the obligations “generate additional costs for both companies and administrations, thus undermining the overall objective of improving competitiveness, not only in the bioeconomy sector, but also in a number of other sectors, including livestock, and adapting forests to climate change through active and sustainable forest management,” the ministers point out. Not only that: the letter denounced “the concrete risk that the increase in raw material prices, caused by the complex obligations” of the regulation, “leads to an increase in production costs and prices, with the associated risk that our producers relocate their production outside the European Union.”
Another problematic aspect, according to the EU countries, is the complete traceability of raw materials within the EU market, which, according to the ministers of the 18 member states, “will be extremely difficult, if not impossible for some of them“. On the contrary, the letter notes that “excessive and redundant due diligence requirements should be eliminated in countries where agricultural expansion does not significantly reduce forest area” and that, “in countries designated as having a low risk of deforestation, it should be accepted that existing national systems are sufficiently robust to demonstrate that compliance with the EUDR can be adequately monitored.” For example, for the ministers “it is essential to simplify requirements for raw materials and products already placed on the EU market, as well as for farmers and foresters in countries or regions with negligible deforestation risk“. Furthermore, “it is essential to facilitate a better integration of the existing national forest datasets of the Member States with the Commission’s information system”.
Finally, “in the context of a general desire to simplify EU legislation, we reiterate that many member states have already expressed a strong need for a more substantial reduction of administrative burdens” related to the Deforestation Regulation. And “we therefore urge the European Commission to rapidly include the Deforestation Regulation in its simplification plans to ensure a coordinated and effective implementation of the EUDR across the EU”. Whereas, while waiting for the Commission’s simplification proposals to be formulated, “it might be appropriate to further postpone the date of application of the regulation.”
English version by the Translation Service of Withub
