Dear Commissioner Roswall,

The undersigned companies, non-governmental and multi-stakeholder organisations wish to encourage you to oppose any proposals to reopen the EU Regulation on Deforestation-Free Products (EUDR) at the conclusion of the review being conducted by the Commission, scheduled to report in April

The company signatories to this letter, together with their value chain partners, including smallholder farmers, have been actively preparing for and investing in compliance with the provisions of the EUDR, which we have consistently supported. These efforts have been made in good faith that the European legislative framework and timeline were reliable. Many producer countries, similarly, have made significant investments in measures, such as national traceability systems, designed to meet the requirements of the EUDR and to keep smallholder farmers connected to EU markets.

If the regulation is reopened yet again after the April review – for a third time before its application – all these investments will be put at risk. Reopening the regulation would introduce considerable uncertainty. As the two previous reopenings have shown, the outcome of such a political process is unforeseeable. It would deeply undermine trust in the EU’s regulatory commitments and alienate business partners and stakeholders in producer countries. In a world in which the international rule of law is increasingly under threat, the EU should avoid becoming another unreliable partner for producer countries, damaging future prospects for international trade and partnerships.

The EUDR as recently amended is not perfect – another proof that constantly changing the legal text does not guarantee resolving all issues. Remaining uncertainties can and must be addressed through further guidance and FAQs, and through initiatives such as the community of practice currently being established to bring together operators and competent authorities to discuss implementation challenges and best practices. No further amendment is needed if the Commission properly defines the details of the respective roles and responsibilities under the newly revised EUDR.

This should be coupled with adequate support for producer countries and local producers, especially smallholders – the source of much of the data needed for implementation – to ensure that costs are not unfairly transferred back up the supply chain, through the Team Europe Initiative and related international partnerships.

The future prosperity of EU consumers and businesses, and farmers overseas, rests on sustainable and secure supply chains. Deforestation, climate change, and human rights abuses put at risk the future of many of the agricultural commodities covered by the EUDR. The regulation represents an innovative effort to address these problems, building on previous experience with the EU Timber Regulation. Coupled with generous support for producer countries, it offers the best chance to achieve sustainable and secure supply chains.

We therefore encourage you to support an outcome of the April review that focuses on timely and effective implementation, to ensure that the EUDR can function in a proportionate, inclusive and legally certain manner. No further amendment is needed. Please do not reward companies that have not invested in time, even after two delays. Please oppose any reopening of the EUDR to further negotiation. 

On behalf of:

Alliance pour la Préservation des Forêts –
Alliance for the Preservation of Forests
Association Technique Internationale des
Bois Tropicaux – International Tropical
Timber Technical Association
Barry Callebaut
Bel
Café Dagobert
Canopée
Anne Caron, le café de spécialité
Cérélia
Danone
Envol Vert
Expanscience Labaratoires
Fair Trade Advocacy Office
Ferrero
Groupe Baronie
Jeff de Bruges
Lechef Premium
Mighty Earth
Nestlé
Planète Urgence
Rainforest Alliance
St Hubert
So-B-Green
Socfin
Sogescol
Solidaridad
Tony’s Chocolonely
Valrhona
VOICE Cocoa Network
VOCAL Coffee Alliance

This letter is organised by the EU Sustainable Supply Chains Coalition, but is open for signature by any company, NGO, certification organisation or multi-stakeholder initiative directly involved in implementing, or affected by, the EUDR.

If you would like to sign, please fill in this online form no later than 18:00 CEST on Tuesday 31 March. The lists of signatories to the letter will be regularly updated. 

Get in touch

For more information, please contact Virginia Enssle, International and Institutional Manager at the FTAO, at enssle@fairtrade-advocacy.org