Calls for a postponement of the EUDR, which - with a few exceptions - is to be applied from December 30, 2024, are currently being directed at the EU from various directions. Warnings of possible market turbulence and bottlenecks are coming in from both member states and countries that import into the EU. A few months before the EUDR is implemented, much is still very unclear. In the timber trade, this includes especially the open question of supplier protection if geocoordinates of the origin of the timber must be passed on to the customer or the customer's customer when checked. In order to circumvent this flaw, access to geocoordinates in particular may be restricted - but remain a mandatory field in the system, even if some countries of origin, such as China, will hardly provide clear information. In addition to missing conversion factors, Chinese coordinates deliberately contain an error source of several hundred meters, which is intended to serve national security. Other issues are the emerging differences in the severity of penalties for violations and the question of how exactly the working conditions at the site of timber harvesting should be checked.

In forestry within the EU, the question of the usefulness of geo-coordinates is being raised in many places, if deforestation could be ruled out purely by law. It is very doubtful, however, that the EU would see it the same way, as no law can offer 100% certainty. For example, there may be different views from country to country as to whether road construction can be seen as deforestation or not. Nevertheless, according to some EUDR specialists, specifying the entire operational or joint operational area as geo-coordinates should be always an option and reduce the bureaucratic effort in EU forestry somewhat.

It is also being discussed that the list of countries with a low or high risk is not expected to be drawn up until the end of December, which would offer little targeted preparatory work or relief on the respective "front". The suggestion is being discussed that one should start with countries that are likely to be low-risk, as their classification is quicker, and the "more difficult cases" are saved for last. This could help to ease the burden if the findings are communicated at an early stage. However, it could also be understood that the effectiveness of the EUDR could be dampened if high-risk countries cannot be identified in a timely manner.

There is still so much uncertainty in the industry about which data needs to be collected, in what volume and in what format, how it needs to be stored, processed and - above all - where it needs to be entered that some companies are considering giving up at the turn of the year. Recently, it was said that manual data entry will not be planned, but that a user-friendly data interface for automatic input will be made available in good time. Data management within companies alone is likely to provide more than enough effort and pressure for technical upgrades. However, simplifications such as the possibility of summarizing a weekly output in one due diligence declaration are at least considered certain.

The calls for postponement and improvements are correspondingly loud. HDH President Johannes Schwörer fears that the regulation in its current form could lead to distortions in trade relations and even trade disputes with countries that are not directly affected by deforestation and demands: "We should forge alliances against global deforestation and not turn partners against us." There is also the fear that the EU could withdraw itself from trade with the lack of a clear implementation road.

Meanwhile, the European Union's Agriculture and Fisheries Council recently responded positively to Austria's previously submitted proposal "European Agriculture and Forestry: the backbone of a competitive, sovereign and prosperous EU". In the proposal, Austria, together with the member states of the Czech Republic, Finland, Greece, Lithuania, Poland and Slovakia, called on the future Commission to strongly reconsider the time frame set for the application of the EUDR and to adequately take into account serious concerns related to its implementation.

Following the statements in the EU Agriculture Council, the composition of the committees in the European Parliament and the composition of the Commission will now determine further developments surrounding the EUDR. The next meeting of the Agriculture Council is scheduled for September 23, 2024, and it is still uncertain whether the EUDR will be put back on the agenda.

Industry associations such as the European Timber Trade Federation ETTF continue to advocate for improvements and postponement of the entry into force, but still consider this to be unlikely. According to GD Holz, for example, one can conclude from experience that the fact that some EU countries have not even appointed an appropriate authority to monitor compliance with the EUDR will not be an obstacle just like when the EUTR came into force - nor will the lack of guidelines.

Check our software solution to help you comply with your EUDR obligations: https://eudr.fordaq.com