Burden falls on farmers in ensuring EU deforestation free supply chains

02 April 2024


By Jenny Brunton, Senior European Policy Advisor, British Agriculture Bureau

From 30 December 2024, new EU legislation that aims to reduce deforestation by ensuring that products consumed on the EU market do not contribute to deforestation and forest degradation worldwide will be enforced. The regulation introduces mandatory due diligence rules for all operators and traders who place, make available or export the following commodities from the EU market: beef, palm oil, timber, coffee, cocoa, rubber and soy.

The co-legislators set the cut-off date of the new rules as 31 December 2020, meaning that only products that have been produced on land that has not been subject to deforestation or forest degradation after 31 December 2020 will be allowed on the Union market or to be exported.

Businesses of all sizes that trade in the selected products will have to meet stringent due-diligence obligations that trace the products they are selling back to the plot of land where it was produced. The European Commission will establish a bench-marking system which ranks countries according to their risk of deforestation: low, standard and high. While no country or commodity will be banned, companies placing products on the EU market will be obliged to demonstrate that their supply chains are not contributing to deforestation. They can use satellite monitoring tools, field audits, capacity building of suppliers or isotope testing to check where products come from.

Farmers will be required to prove that any beef sold on the EU single market, including in Northern Ireland, has not come from cattle raised on land that was deforested to make space for grazing. They will also have to demonstrate they are not using animal feed that contains soy or palm oil that is driving deforestation abroad.

However, the traceability requirements are unclear and there remains many questions over what information is required and lack of definitions which have not been answered.

The British Agriculture Bureau has been highlighting the concerns of UK farmers in meeting these burdensome requirements and has joined with wider European industry to call for clarity, simplification, and any necessary delay to ensure feasible implementation.

Copa Cogeca stated that “Since the publication of the Commission's proposal of the EU Deforestation and Forest Degradation Regulation (EUDR) on 17 November 2021, primary producers have supported the objective of the EUDR and presented many times their views to facilitate an implementation that should secure legal certainty to operators. In the meantime, it has become obvious that key parts of the final text that remained unclear are to be interpreted so strictly that their implementation will lead to a high level of administrative burden and costs. It will therefore not be possible to implement the EUDR in practice. Furthermore, it is not foreseeable that adequate framework conditions will be finalised sufficiently in advance of the deadline for implementation.”

Many EU members have made similar statements and in early April 2024, a group of 20 EU Member States, led by Austria, called for a temporary suspension and revision of the regulation. The Austrian delegation argues that the new obligations will place a “disproportionate administrative burden” on the European agricultural sector and are demanding to “significantly” extend the period for implementing the measures, exempt EU small farms and producers in countries from the new due diligence rules where the risk of deforestation is low.

However, for now, the European Commission is resisting calls to postpone the implementation of the law.

Northern Ireland

The European Commission has notified the UK Government that the regulation will be applied in Northern Ireland under the Northern Ireland Protocol. This will make it obligatory for companies to undertake due diligence for any goods sold into Northern Ireland, and therefore the EU single market, including goods from GB. The UK Government is obliged to appoint a Competent Authority to implement these checks in Northern Ireland, but has yet to do so.

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