Coalition call to EU Commission and Member States for clarifications and workable solutions for EUDR implementation

On 28th March 2024, Bioenergy Europe together with other 21 sectoral organisations expressed concerns regarding the slow pace of preparation of EUDR-related legislative acts. Signatories draw attention to gaps and delays in the setting of the mandatory Information System, and highlight the lack of implementation guidance for operators and traders.

Operators and traders, including those from the Bioenergy sector, are preparing their supply chains, systems and due diligence processes to comply with the EUDR. Their objective is to develop workable solutions to align with the EUDR provisions, while limiting administrative burdens.

Significant information gaps, lack of appropriate technical solutions and misconceptions on the value chain operations, represent an obstacle at this stage. As an integral part of the sector, Bioenergy Europe calls for a workable EUDR implementation.

• Urgently resolve legal uncertainty/lack of clarity of essential provisions.
Operators have been calling for practical guidance since the entry into force of the Regulation. But 8 months away from the implementation date, many questions are still pending and the pace with which they are addressed is too slow. Although the Commission has provided some clarity in its FAQs and upcoming guidance document, the information is still insufficient/limited. To make the implementation practically feasible, stakeholders along value chains should be included in the guidance elaboration.

• Make the Information System quickly up to operational standard.
The Information System will be a key element to the implementation of the EUDR by operators and traders. Yet, the pilot test has revealed flows that could hinder compliance, posing unnecessary burdens for operators and traders without any added value to the Regulation goals. Moreover, the current System planning does not provide enough time to train personnel to use the System and connect the internal systems to the Information System. It is essential to include companies in the design of the system.

• Clarity on the timeline of the Country Benchmarking System.
The announcement on the Country Benchmarking System seems to imply that all countries will be classified under standard risk before the benchmarking system is ready. The sector highlights the implications of this, since operators sourcing commodities in countries or regions with low or no evidence of deforestation or forest degradation will not be able to use simplified rules.

Download the letter for more details.