The regulation on deforestation (2023/1115) is a cornerstone for trade reciprocity, sustainability, and fair value chains for agriculture and food products. A postponement of one year is now unavoidable considering the late presentation of the implementing rules, but any further delay should be avoided.
In order to comply with WTO requirements and guarantee a fair treatment for all operators worldwide, the regulation on deforestation has been designed to cover the entire planet, regardless of the level of deforestation risk in the countries covered.
A simplified due diligence procedure has been set up to avoid placing a disproportionate burden on operators producing and marketing raw materials from countries with a low risk of deforestation.
However, as highlighted in previous analysis by Farm Europe, this simplified due diligence procedure only allows a partial derogation from the administrative requirements and data collection, placing unreasonable burdens on operators for low or zero deforestation risks.
Simplification yes, dismantling no.
Therefore, the amendments proposals seeking to create a “no risk” category goes in the right direction. But any further modifications would change the nature and be a blow to the level of ambition of the regulation. In particular, to secure a robust regulation, the responsibility of important global operators should not be diluted.
Corrections should be limited to the parts of the text that threaten its own credibility, namely the ultimate risk of having a new standard that would weigh more heavily on EU farmers and food producers, faced with a fussy and disproportionate implementation of the regulation, than on global actors.
These changes should be made quickly, taking into account the need to limit as much as possible the delay in the implementation of this important regulation, to avoid destabilizing European value chains and threatening their fragile economic equilibrium.
A full implementation from the European Commission needed.
In the meantime, the implementation of Recital 31 of the regulation which calls upon the European Commission to build a platform providing an “early warning system” to assist the competent authorities, operators, traders and other relevant stakeholders must be fully put into practice, which is not the case until now.
This plateform has been added by the co-legislator to the Commission’s initial proposal to provide “continuous monitoring and early notification of possible deforestation or forest degradation activities”, and to be operational as soon as possible. It is be a building block for an easy, uniformed and simplified implementation of the regulation by third countries, and in particular for developing countries that should be set up.
O artigo foi publicado originalmente em Farm Europe.
