COPA and COGECA welcomed the December 2024 decision to extend the start of implementation of the EU Deforestation Regulation (EUDR). At the same time, they reiterate their call for a focus on significant simplification. This call is linked to our concerns about the practical applicability of the Regulation, its lack of proportionality, the considerable administrative burden it imposes, and the legal uncertainties and diversion of goods flows that it is likely to generate. These issues are also increasingly recognized by MEPs and Agriculture Ministers, who have publicly called for substantial simplification and a proportionate approach to the implementation of the EUDR.

In view of these concerns about the proportionality of the EUDR, they emphasize the urgent need for a more targeted, risk- and feasibility-based implementation of the EUDR, going beyond what is provided for in the current Regulation. Despite the European Commission's efforts to clarify the Regulation through guidance documents and frequently asked questions (FAQs), these initiatives have not provided significant improvements that address our main concerns, although they welcome some clarifications. Crucially, these documents lack legal force and are subject to differing interpretations across Member States. Therefore, simplification should be achieved directly through amendments to the Regulation.

They recognize the Commission's stated commitment to simplification in its 2025 Work Programme, and in particular the potential of upcoming omnibus legislative packages. "These initiatives represent an opportunity that must not be missed," they believe. They therefore urge the Commission to include a comprehensive review of the EUDR as part of these simplification proposals.

They also remain fully committed to constructive dialogue and are ready to contribute to a regulatory process that enables the EUDR to achieve its environmental objectives without compromising the viability of responsible operators throughout the supply chain.