Simplification of the EUDR: difficulties in implementing the EUDR and the need for substantial simplification

Any other business item requested by Luxembourg and Austria supported by Bulgaria, Croatia, Czechia, Italy, Finland, Latvia, Portugal, Romania and Slovenia in view of the Agriculture and Fisheries Council meeting on May 26, 2025:

Sustainable forest management is necessary to develop climate-resilient forests, ensure species diversity and enhance bioeconomy with multiple products. Regulation (EU) 2023/1115 contributes to reducing greenhouse gas emissions and global biodiversity loss by minimising deforestation and forest degradation worldwide. Thanks in particular to European policy, between 1990 and 2015 the area covered by forests and wooded areas in Europe increased by 90,000 square kilometres. Land-use planning is regulated and is included in European agricultural policy, particularly in a coercive way through CAP cross-compliance.

Given the considerable complexity of the Regulation's provisions, and in order to enable farmers and foresters and competent authorities to meet their obligations, the Commission proposed postponing the date of application of the Regulation until 30 December 2025. This proposal was adopted by the co-legislators in December 2024, accompanied by a statement from the Commission attesting to its commitment to reducing the burden on businesses by eliminating unnecessary administrative burdens. Guidelines for simplifying and reducing the administrative burden were adopted by the European Commission in April 2025.

Nevertheless, the requirements imposed on farmers and foresters remain high, if not impossible to implement. They are disproportionate to the objective of the regulation, which is to prevent deforestation where it actually occurs.

This is why, in the current context of a general desire to simplify EU regulations, many Member States have already come out in favour of a more substantial reduction in the administrative burden associated with Regulation (EU) 2023/1115 on deforestation.

There are several ways in which this could be simplified, including

• Introduce countries or regions with insignificant risk of deforestation, for which operators do not have to record the geolocation of agricultural land or forest land used and the competent authorities do not have to carry out checks on products from these areas, provided that national laws and practices effectively limit the risk of deforestation and forest degradation.
• In countries or regions belonging to the negligible or insignificant risk, make it possible to set up a regulated compensation mechanism, applicable only outside areas of primary or protected forests with high biodiversity value, where the felling of trees could be offset by certified afforestation of an equivalent area in the same country. The criterion is to maintain or increase the wooded area of the defined zone.
• Introduce the possibility of carrying out controls based on a risk analysis, with no minimum rate.
• Reduce reporting and documentation requirements to a strict minimum the simple declaration of surface area for the CAP could be sufficient.
• Implement strict controls on imported products to minimise the risk of fraud.

We therefore call on the European Commission to include the deforestation regulation in its simplification plans.

Pending the Commission's proposals, it would be advisable to further postpone the date of application of the regulation.