European timber organisations have made a last, united call for changes to be made to the EU Deforestation Regulation (EUDR) before it comes into force this December.
Eighteen organisations from various sectors, including timber, panels and packaging groups, called for an EUDR Information System “without flaws and technical constraints, aligned with business practice”.
The coalition underlines that the Information System must be operationally workable and aligned with real business practices.
The EUDR Information System, which represents the backbone of the traceability feature of the EU regulation, is aimed to prevent products linked to deforestation from entering the EU market.
Particular coalition concerns relate to DDS aggregation, technical limitations of the TRACES-based system, the usability of simplified declarations for SMEs and micro-enterprises and the lack of clear procedures in the event of system disruptions or outages.
The coalition said it was committed to fighting deforestation and supporting a workable implementation of the EUDR.
“Ensuring that the Information System meets operators’ and traders’ requirements and runs smoothly and dependably is a critical requirement for seamless trade flows and critical supplies for the EU market,” the coalition said.
Commission services are revising the Information System to integrate amendments introduced to the EUDR and to implement targeted technical improvements aimed at enhancing performance, resilience and user-friendliness.
But the coalition is reiterating its urgent call to fix unnecessary technical constraints and highly problematic shortcomings of the system.
It highlights:
• Due Diligence Statement (DDS) aggregation, as a “major gap”. While the Commission’s Report indicates that the system will allow grouping of DDS reference numbers, in practice, the Coalition says significant technical constraints are imposed which severely limit or even prevent meaningful aggregation.
• The use of an existing data base developed for other purposes (TRACES), and not adapted to the needs of the different supply chain players, is not providing necessary functionalities
• Regarding simplified declaration, the version presented by the Commission to relevant stakeholders is not usable for micro and small operators. Primary producers currently lack reassurance that the promised proportionality and simplification measures will be effectively implemented. In addition, there is no certainty that the databases established at the EU or Member State level will be accessible and integrated into the EUDR IT system.
• For countries and activities with a high proportion of SMEs and particularly micro-enterprises, with scarce IT resources, no dedicated compliance teams, nor in-house capacity to manage digital traceability systems, and relying on manual workflows, the current design of the Information System might constitute a structural barrier to market access.
• Advanced notification of any modification affecting the Information System is also necessary to ensure legal certainty, operational continuity and adequate preparedness of both competent authorities and economic operators. Such information is essential for all concerned actors to adapt internal procedures and technical systems in a timely and compliant manner.
“If the flaws and constraints are not lifted, operators and traders will be thwarted
in their efforts to comply with the Regulation,” added the Coalition.
“They will incur unnecessary costs to adapt operations and logistics, for additional data manipulation; they risk penalties due to human processing errors and ultimately can be discouraged from producing, processing and trading the commodity and from serving the EU market.”
Coalition signatories include:
• CEI-Bois (The European Confederation of Woodworking Industries)
• European Panel Federation
• European Organisation of the Sawmill Industry
• European Parquet Federation
• European Confederation of Paper Industries
• Bioenergy Europe
