Update EUDR: Post­po­ne­ment of the date of appli­ca­ti­on to be expected

Fol­lo­wing the appr­oval of the Coun­cil in the urgent pro­ce­du­re, on 14 Novem­ber 2024 the EU Par­lia­ment also appro­ved the post­po­ne­ment of the date of appli­ca­ti­on of the EUDR for lar­ge mar­ket par­ti­ci­pan­ts and trad­ers to 30 Decem­ber 2025, and for SMEs to 30 June 2026, and also deci­ded on sub­stan­ti­ve chan­ges. Howe­ver, the chan­ges still have to be for­mal­ly adopted befo­re they enter into force.

The back­ground to this was the cri­ti­cism of EU mem­ber sta­tes and addres­sed eco­no­mic actors that the tran­si­ti­on peri­od was too short for com­pa­nies to imple­ment the new requi­re­ments intern­al­ly. Due to the bureau­cra­tic effort invol­ved in coll­ec­ting infor­ma­ti­on, in par­ti­cu­lar, the geo­da­ta of the pro­per­ties and the pre­pa­ra­ti­on of due dili­gence decla­ra­ti­ons, exten­si­ve and cos­t­ly inter­nal res­truc­tu­ring is neces­sa­ry for the most part.

In addi­ti­on, on 14 Novem­ber 2024, the EU Par­lia­ment also adopted sub­stan­ti­ve chan­ges to the text of the regu­la­ti­on, which are based on amend­ments by the EPP. A total of 15 amend­ments were tab­led, which also pro­vi­ded, for exam­p­le, for an exten­si­on of the tran­si­tio­nal peri­od to 24 months, cer­tain exemp­ti­ons from dea­ler obli­ga­ti­ons and a zero-risk cate­go­ry for count­ries that do not need to com­ply with increased due dili­gence obli­ga­ti­ons. Six of the­se moti­ons were with­drawn befo­re the vote, one was rejec­ted and eight were accepted.

For exam­p­le, a nar­row agree­ment was rea­ched on the intro­duc­tion of a zero-risk coun­try cate­go­ry, so that the core obli­ga­ti­ons of the regu­la­ti­on do not app­ly to the­se countries/regions and thus do not impo­se any new bureau­cra­tic obli­ga­ti­ons on eco­no­mic ope­ra­tors. For count­ries that have no or only a negli­gi­ble risk of defo­re­sta­ti­on, no increased due dili­gence obli­ga­ti­ons would have to be ful­fil­led, but only docu­men­ta­ti­on obli­ga­ti­ons. This cate­go­ry would include count­ries who­se forest area has remain­ed sta­ble or increased com­pared to 1990, which have signed the Paris Cli­ma­te Agree­ment and inter­na­tio­nal con­ven­ti­ons on human rights and the pre­ven­ti­on of defo­re­sta­ti­on, and whe­re regu­la­ti­ons to pre­vent defo­re­sta­ti­on and pro­tect forests are strict­ly imple­men­ted and moni­to­red at the natio­nal level. Due to the sub­stan­ti­ve chan­ges, ren­ego­tia­ti­ons bet­ween the EU Par­lia­ment, Com­mis­si­on and Coun­cil are now neces­sa­ry, as only an exten­si­on of the tran­si­ti­on peri­od had ori­gi­nal­ly been agreed.

The amend­ments adopted by the EU Par­lia­ment have now been refer­red back to the respon­si­ble com­mit­tee for inter-institutional nego­tia­ti­ons with the Coun­cil. The amend­ments must then be for­mal­ly appro­ved by the Coun­cil and also by the Par­lia­ment and published in the Offi­ci­al Jour­nal. Howe­ver, this must be done befo­re the plan­ned start of vali­di­ty on 30 Decem­ber 2024. Tri­lo­gue nego­tia­ti­ons are curr­ent­ly under way, but no agree­ment has thus far been rea­ched on sub­stan­ti­ve chan­ges. The final vote in the Coun­cil is curr­ent­ly plan­ned for 2 Decem­ber 2024 – the pro­ce­du­re must be com­ple­ted by mid-December at the latest.

Con­clu­si­on

It remains exci­ting: Accep­tance of the amend­ments would signi­fi­cant­ly wea­k­en the goal of the regu­la­ti­on and its enforce­ment, but would also be accom­pa­nied by strong bureau­cra­tic sim­pli­fi­ca­ti­ons for com­pa­nies. First of all, an exten­si­on of the tran­si­ti­on peri­od is to be wel­co­med from a busi­ness point of view. We will con­ti­nue to report.

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