The signatories of this open statement recall that the effectiveness of any legislative framework depends on its workability, legal clarity, and predictability. The recent amendments proposed by the European Commission to the EU Deforestation Regulation (EUDR) after the announcement of a further postponement on 23 September, prolong a situation of costly uncertainty and unrealistic implementation timelines. The new proposal, and the very challenging timeline to have it approved, risks undermining both the credibility and the practical enforcement of the Regulation, while placing European operators in an untenable position of legal and operational uncertainty.
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The changes introduced by the Commission are substantial and deserve appropriate time for stakeholders, policy makers and Member States to analyse and discuss them.
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The proposal further fails to reflect the operational reality of the market, where medium-sized and large companies routinely interact with small and micro-enterprises within integrated supply chains. As a result, establishing different application dates – with large and medium enterprises required to comply from 30 December 2025, and small and micro-enterprises benefiting from twelve additional months, will, in practice, force all operators to comply from the same date.
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Our sectors continue to face a serious deficit of clarity and legal certainty, which conflicts with a fundamental right guaranteed under EU law and which remains indispensable for sound business operations, competitiveness, and investment.
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We therefore urge the European Commission to introduce a “stop-the-clock” mechanism that allows for policymakers to have a proper and a comprehensive assessment of the Regulation’s impact and implementation. Such a reassessment should aim to identify genuine simplification measures and to render the EUDR obligations truly workable, while fully preserving the Regulation’s legitimate environmental objective of combating deforestation, a goal strongly supported by the signatories of this open statement.