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Report from
Europe
Debate continues on EUDR implementation
The latest European Commission (EC) proposal for a
phased introduction of the EU Deforestation Regulation
(EUDR) and simplification of its obligations for
businesses is expected to be voted on by Members of the
European Parliament (MEPs) at their 24-27 November
Plenary.
However, more than 20 industry bodies representing
sectors covered by the EUDR have signed a statement
calling on European policy makers to ‘stop the clock’ on
implementation. The statement says additional time is
needed for the latest proposed amendments to be
deliberated and for businesses to adapt. This
recommendation is also being backed by some EU
member state politicians.
The EC initially proposed on 23 September delaying
EUDR implementation another 12 months, after it had
already been pushed back a year from the original
introduction date of December 2024. The reason given
was that the EUDR’s Traces NT administrative IT system
was not ready to cope with the volume of compliance data
businesses would upload under the regulation.
This proposal had provoked debate in industries affected
for and against and among MEPs and civil society.
Environmental NGOs were strongly opposed, with 225 of
them from 42 countries signing up to a statement ‘Hands
off the EUDR’.
Subsequently the EC came up with its alternative proposal
on 21 October. This is for the EUDR implementation date
of 30 December 2025 to stand for large and medium
companies. However, under the proposal they would have
a six-month transition period before checks start. Small
and micro businesses would have until 30 December 2026
before the EUDR implementation.
On 4 November coordinators of the EU Committee on
Environment, Public Health and Food Safety (ENVI)
decided to request the use of the urgency procedure
regarding the EC proposal so a parliamentary vote can
take place on it quickly. According to an EU Parliament
spokesperson, MEPs will consequently vote on the use of
the urgency procedure in this case at the 12-13 November
plenary, then vote on the proposal itself at the following
session later in the month.
But the ’stop the clock’ statement from industry bodies,
coordinated by the European woodworking industries
confederation CEI-Bois, says this does not give
businesses sufficient time to absorb the proposed changes
to the EUDR. It also highlights problems with the different
implementation dates for businesses according to size.
The statement signatories cover the range of FERCs
sectors affected by the EUDR, from wood and furniture,
to tanning, animal feed producers, the meat trade and
chemicals businesses.
The statement says: “The new proposal and the very
challenging timeline to have it approved risks undermining
both the credibility and the practical enforcement of the
Regulation, while placing European operators in an
untenable position of legal and operational uncertainty.”
It adds that the EUDR changes proposed by the EC are
‘substantial’ and require time for stakeholders, policy
makers and EU member states to analyse and discuss.
“This is exceptionally difficult considering the deadline of
30 December 2025 currently in place [for EUDR
implementation],” says the statement.
It raises the issue that large downstream industries, which
have adapted their IT systems to interface with the EUDR
Traces system, will have to change them again.
On the different EUDR implementation dates for
businesses dependent on their size, the statement says this
‘fails to reflect the operational reality of the market, where
medium-sized and large companies routinely interact with
small and micro-enterprises within integrated supply
chains’.
“As a result, establishing different application dates, with
large and medium enterprises required to comply from 30
December 2025, and small and micro-enterprises
benefiting from twelve additional months, will, in practice,
force all operators to comply from the same date,” it
states. “The interdependence of companies within the
value chain makes the proposed postponement illusory, as
smaller operators will be required to align immediately to
maintain business relations.” The statement urges policy
makers to reassess the EUDR to ‘identify genuine
simplification measures and to render obligations truly
workable’.
One thing it does not mention is a preferred alternative
date for EUDR implementation. However, some EU
politicians also backing the ‘stop the clock’ lobby are
calling for the EC to revert to its 23 September proposal to
push the regulation’s introduction back a further 12
months.
According to EU news platform Euractiv, a note to this
effect has been submitted by Austrian politicians. They
are also backing calls to add a ‘zero risk’ category into the
deforestation risk classification of supplier countries
which currently rates them high, medium and low.
“Sustainable forest management is part of Austria’s
DNA,” Austrian Agriculture and Environment Minister
Norbert Totschnig told Euractiv. “However, in its current
form, the EUDR risks penalising those who are already
practising sustainable forest management.”
At the latest meeting of the EU Environment Council, 15
countries, including Italy and Poland, backed the Austrian
call.
See:
https://ec.europa.eu/commission/presscorner/detail/en/ip_25_246
4
and
https://www.euractiv.com/news/austria-to-push-for-stop-the-
clock-on-deforestation-rules-at-council/
and
https://www.euractiv.com/news/deforestation-rules-divide-eu-
institutions-as-delay-gains-ground/
and
https://www.clientearth.org/media/h4diqpa2/cso-
statement_eudr_delay_october-2024.pdf
and
https://www.cei-
bois.org/_files/ugd/5b1bdc_d6fb86da02fa4e29990025c7e89f013
f.pdf
Breaking news, 12 November
EU Member States failed to reach common position on
proposed changes to deforestation regulation.
See:https://www.business-humanrights.org/en/latest-
news/eu-member-states-fail-to-reach-common-position-
on-proposed-changes-to-deforestation-regulation/
BMRC moves to new International Forest Governance
Hub
To underpin the development and growth of the Broader
Market Recognition Coalition (BMRC) of tropical
countries, its secretariat is moving to a new International
Forest Governance Hub (IFGH) set up by the European
Forest Institute (EFI).
The BMRC set out its Roadmap at a summit in Bali in
2023. Members undertake to develop their National
Sustainable Forestry Systems (NSFS) and to have them
independently validated against internationally accepted
good forest governance principles and indicators.
The objective is then to promote and communicate these
systems worldwide to support access to markets globally
and increase trade in member countries’ sustainably and
legally produced timber and wood products. This, in turn,
is intended to incentivise further development and
strengthening of sustainable forestry through NSFS, to
encourage wider international implementation of such
systems and attract more countries into the BMRC.
The BMRC is also a forum for members to exchange
information, experience and best practice to support
further development of their NSFS. The six founder
members are Cameroon, Ghana, Guyana, Indonesia,
Liberia and the Republic of the Congo. A number of other
‘associate’ countries are reported to be interested in
joining.
To date the UK timber trade body, Timber Development
UK, has provided secretariat support services for the
BMRC, supported by a grant from the Forest Governance
Markets and Climate programme (FGMC) of the UK
Government’s Foreign, Commonwealth and Development
Office (FCDO).
According to David Hopkins of the Timber Development
UK (TDUK), the secretariat functions of the BMRC
should pass over to IFGH early in 2026.
He confirmed that TDUK will continue its involvement as
a stakeholder with the BMRC. It plans to keep working
with FGMC during 2026 to undertake a range of activities
in support. These are aimed at ‘strengthening private
sector engagement with NSFS within producer countries
and with importers looking to buy from those countries’.
It is looking to produce a ‘Buyers Guides’ to each tropical
country in scope. These will explain each NSFS system,
what they cover, what due diligence information buyers
should collect, and what products are available from each
country. The guides will be promoted in the UK, EU and
globally.
TDUK will also back a series of in-person workshops in
producer countries to allow importers to learn first-hand
what the NSFS system looks like in each country and also
to understand the levels of compliance and improvement
currently taking place within them.
The BMRC website explains that it is a multi-stakeholder
organisation, with representatives of government, private
sector and civil society involved in decision making. It
also gives information on how other tropical timber
producing countries can become members, and non-
tropical country associates of the organisation.
See - http://www.oxfordhr.com.fiennes.org/jobs/leadership-team-
international-forest-governance-hub/
and
www.forestgovernance.org
and
https://efi.int/
and
https://timberdevelopment.uk/
Certification foundation of Danish imports
A new report from the Danish Timber Trade Federation
(DTTF) shows that 97% of the wood imported by its
members in 2024 was certified under FSC and/or PEFC
standards.
The DTTF says certification remains a central tool for the
timber industry, both to ensure responsible forest
management and to provide the necessary traceability and
transparency throughout the wood value chain. It describes
it as the ‘key to ensuring transparency throughout the
wood value chain, playing an essential role in the green
transition’.
“With certification, we can trace the wood all the way
back to the forest, where we can document the extensive
environmental, social and climate considerations that go
into forest management,” says DTTF Director Jakob Rygg
Klaumann. “This gives confidence to consumers,
businesses, and authorities that the wood can be followed
from the forest to the construction site or the furniture
store,”
Since July, new and stricter climate requirements have
been introduced in Danish building regulations, and they
will continue to tighten towards 2029. This, says the
DTTF, will increase demand for biogenic materials, and
documented, sustainably produced timber will play an
even more important role.
In 2023, DTTF members reached their 2025 target of
having at least 95% of imports certified and this rose to
97% last year.
The figure covers softwood, panels, and hardwood.
Almost all softwood and panels are certified (99% and
97% respectively). The share of certified hardwood is
lower at 63%, but has increased steadily since 2020, when
the first measurement was taken.
See - https://dktimber.dk/ny-bruger/
CSRD reports highlight construction’s sustainability
commitment
First reports on their environmental performance from the
EU construction and real estate sectors under the EU
Corporate Sustainability Reporting Directive (CSRD)
underline the increasing significance attached to
environmental performance.
That is according to a report from construction market
forecasting network Euroconstruct. It says the emphasis in
corporate policy is increasingly on ‘environmental social
and governance integration’, ‘stakeholder-driven
materiality’ and decarbonization – especially Scope 3
emissions. It adds that biodiversity and water management
in the building industries are increasingly strategic, driven
by regulation and ecological risks.
“Companies are adopting systemic approaches to
sustainability, transparency, and long-term resilience,”
said the report.
Based on analysis of the CSRD reports of 41 companies
from 15 different countries by professional services
network BDO, Euroconstruct says companies in the
building sector are ‘progressively integrating ESG
(Environment, Social and Governance) criteria into their
business models and value chains’.
“Decarbonization is a central pillar of the assessed
companies’ CSR strategies, but the sector faces significant
challenges due to the dominance of Scope 3 emissions,”
states Euroconstruct. “Scope 3 emissions account for
nearly 98% of the sector’s carbon footprint. While 61% of
companies have a transition plan (above the cross-sector
average), only 15% use internal carbon pricing.”
Biodiversity is also becoming an increasingly key issue for
the sector, it reports. “Biodiversity and water resource
management have become structuring issues, driven by
regulatory frameworks and ecological dependencies,” it
says. “63% of [the companies covered by the BDO
analysis] now report biodiversity indicators, far above the
average for all sectors.
Companies are mapping water stress and quantifying
biodiversity impacts across their value chains. These
efforts reflect a growing recognition that managing
ecological risks is not only a compliance requirement but a
strategic imperative for the long-term.”
See: https://www.euroconstruct.org/news/csrd-in-practice-
sustainability-disclosures-from-the-construction-real-estate-
sectors/
Bio-based building needs better supply chains
According to a study from the German-based think tank
Bauhaus Earth (BE) and the Kuehne Climate Center
(KCC), more efficient supply chains are needed to drive
uptake of bio-based materials in construction, including
timber.
The study, Bio-based Construction and the Role of
Logistics, looks at the state of bio-based construction
product supply chains in Germany, Kenya and Indonesia.
It states that with construction and buildings in use
currently accounting for 40% of greenhouse gas emissions
globally, largely due to use of energy intensive materials.
With the world’s building stock set to double by 2060, it
says, the building industry needs urgently to incorporate
more low carbon materials, such as wood and bamboo.
Increased uptake of bio-based products in building will
require regulation and adoption of new standards and
wider steps to encourage demand. But what the study
describes as the ‘missing link’ are strong, stable and
effective supply chains.
Supply chains of bio-based construction materials are still
at an early development stage, even in more advanced
markets, like Germany, it states. To scale their operation
demands good forest management, industrialization of
materials processing and pre-fabrication of reusable
modules, which are currently constrained by ‘regulatory
hurdles and inertia on the demand side.
In emerging markets, says the study, inefficiencies and
fragmentation along bio-based materials’ supply chains
lead to ‘poor alignment of supply and demand and
unnecessarily higher costs’. “For Kenya, we find that the
logistics cost of timber makes up almost 50% of the total
product cost.,” explains Olivia Lamenya KCC.
See –
https://www.kuehne-
stiftung.org/fileadmin/user_upload/Dateien_Stiftung/Documents/
KCC_BE_Bio-
based_Construction_and_the_Role_of_Logistics.pdf
https://www.bauhauserde.org/
https://www.kuehne-stiftung.org/areas/climate/climate-center
Compny size definitions
A reader raised a question on the definitions of company
size in the EUDR.
Please see; https://single-market-
economy.ec.europa.eu/smes/sme-fundamentals/sme-definition_en
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