07.06.2024
As part of the preparations for the implementation of the EUDR, the European Union is implementing the information system that will enable due diligence declarations to be submitted. However, the first steps reveal major challenges.
As part of Regulation 2023/1115, known as the EU Deforestation Regulation (EUDR), the European Commission is setting up a European information system. European operators and traders will have to submit their due diligence declarations before placing their wood (and wood-based) products on the EU market, or exporting them. Development of the system began after the regulation was approved by the European Parliament and the Council in December 2022.
First version of the information system and pilot tests
Pilot tests on the first version of the information system were organised by the European Commission between December 2023 and January 2024, involving 100 stakeholders, including companies from the soy, palm, coffee, beef, cocoa and timber sectors. These tests revealed significant errors and limitations, including:
These problems have given rise to concern among the sectors concerned, who have expressed their concerns by various means, including letters and open letters.
Testing APIs (software gateways)
To enable interoperability between companies' internal systems and the future European information system, the Commission is developing APIs (application programming interfaces). Compliance tests for these APIs began on 27 May 2024 and are continuing without a deadline.
We are attaching to this message the Commission's technical notes (sheet 1, sheet 2, sheet 3, sheet 4) designed to guide these compliance tests. They are also available on the European Commission website, which may update them if necessary.
It is also important to understand that these compliance tests are not a second series of pilot tests, like the one that took place between December 2023 and January 2024. These tests are intended for a technical audience due to the specific knowledge required to access the methods provided and the associated technologies.
Next steps in the development of the system
The Commission plans to conduct ‘train the trainer’ sessions in autumn 2024, in coordination with Member State authorities, to help stakeholders familiarise themselves with the system. User manuals and other self-learning materials, such as video tutorials, will also be made available.
The planned timetable for implementing the system is as follows:
Industry reactions
The federations from the various industries in the sectors concerned are highlighting the potential consequences of a non-functional system, including the impact on the reputation of the European Commission and the competitiveness of EU supply chains. They expressed their willingness to work together to improve the system and made a number of requests:
Many organisations also expressed their wish that the text of the regulation be revised and its implementation delayed, while supporting the intention of the legislation.
For technical questions relating to the information system, please contact: ENV-EUDR-IS-TEAM@ec.europa.eu
For further information:
All the information on the implementation of the EUDR is available on this page. You will also find the FAQ (the latest version dates from December 2023; a new version is expected very soon).
Concerning the country evaluation to be carried out by the European Commission: this activity has been delayed, as the Commission contracted a service provider (Guidehouse Netherlands B.V.) last April.
Although no official announcement has been made, a European Commissioner has stated that publication of the results of the country evaluations will be postponed. This means that all countries will be classified as standard risk when the regulation is implemented.
The Commission is also working on guidelines for each sector. A draft version for the timber industry is circulating, and from our reading, this document does not provide many new operational elements.
The ATIBT remains committed to facilitating the understanding and application of these regulations. Please do not hesitate to contact Caroline Duhesme if you have any questions on this subject: caroline.duhesme@atibt.org
