The EU Deforestation Regulation (EUDR) came into force last year. It is due to start being applied at the end of 2024. After the regulation was adopted, the German Timber Trade Association (GD Holz) pointed to a great many unanswered questions about implementing the EUDR, and the implementation timetable also looks very tight (rushed).

“We agree with the aims of the EUDR,– to prevent illegal logging and deforestation worldwide, but the path towards achieving those aims clearly involves an excessive amount of bureaucratic work. The European Commission has yet to do its homework in many areas, and there is too little time,” stresses GD Holz managing director Thomas Goebel (Thomas Goebel).

GD Holz takes the view that the guidelines urgently needed for the practical implementation of the EUDR are missing. A catalogue of questions and answers of importance to everyone involved is currently available, but in many quarters it is considered inadequate and impractical, and it does not answer the most important questions.

In the opinion of those who took part in the pilot test, the “information system” offered by the EU for submitting due diligence (compliance) declarations does not work satisfactorily. A system for cooperation with the European Commission is currently being developed in order to transmit the relevant due diligence data. It should be stressed that here too the timetable is “very ambitious”.

Another important aspect of carrying out these obligations diligently is the general risk assessment of timber supplier countries. Under the rules of the EUTR (European Union Timber Regulation) currently in force, this is left to the timber importers themselves. The Corruption Perceptions Index (CPI) is usually used as a benchmark. With the EUDR, the European Commission wants to classify this into “low, standard and high risk” categories. GD Holz has information from well-informed staff at European institutions that this classification is being postponed. That makes fulfilling an already complicated monitoring obligation even harder if essentially all imports are classified in the “standard risk” category.

Moreover, many suppliers are currently unable to provide the necessary data (geographical coordinates in particular), GD Holz points out. The situation is made worse by the fact that in China, for example, passing on geodata is difficult or prohibited on security grounds. Although geographical coordinates are available there in some cases, there are no official conversion factors for converting them into the format laid down by the European Union. Even if that were to succeed, the Chinese coordinates may be inaccurate. As a result, the coordinates will always differ from reality by several hundred metres in any direction. The GD Holz association is calling on the European Union to find a positive and swift solution to this situation.

Although there are already years of experience in meeting special due diligence control obligations for timber imports under the EUTR, the EUDR will create considerable additional difficulties in document management and in gathering information (including geodata), say representatives of GD Holz. The obligation the EU Commission has set itself, under which old rules are removed on a “one in, one out” basis, is right only in terms of balance, since the content and the requirements increase considerably.

The European Timber Trade Federation (ETTF) and other organisations have already approached the European Commission with an open statement, asking for the entry into force of the EUDR to be postponed.