The EU Regulation on Deforestation-Free Supply Chains (EUDR)

Deforestation
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The clock is ticking: make sure several commodities and products you want to place on the European market are deforestation-free and compliant with several local regulations by 29th December 2024.

Global forests, as carbon sinks, play an important role in mitigating climate change by absorbing and storing greenhouse gases. The EU is a major consumer and trader of commodities that play an important role on deforestation and forest degradation, risking also their ecosystems worldwidely. To address these matters the EU has now taken a significant step forward by adopting the Deforestation Regulation (EUDR). 

From the date the Regulation entered into force on 29 June 2023 companies have 18 months to comply with the new rules. Small and medium enterprises have a longer transition period, as well as other specific provisions (see timeline).

Unlock insights into EUDR's influence on your sector and products

Curious about how EUDR affects your sector and products? Explore our detailed brochures by selecting your area of interest below.

   

Fast-track your EUDR compliance

The deadline for EUDR compliance is fast approaching. Is your business tuned to be EUDR compliant? Download our comprehensive EUDR Fast Track Implementation Plan now to guide you to be ready in time!

Download fast track compliance implementation plan

What action needs to be taken on these products and commodities?

Certain commodities and products cannot be placed or made available on the EU market (or exported from the EU) unless all three of these conditions are fulfilled:

  • they are deforestation-free (occurring after 31 December 2020);
  • they have been produced in accordance with the relevant legislation of the country of production;
  • they are covered by a due diligence statement (and submitted by the operator on the Commission's Electronic interface).

The above-mentioned due diligence statement certifies that there is no or negligible risk that the products and commodities are non-compliant with the EUDR. 

The EUDR covers commodities or products that consist of, contain or are derived from coffee, cocoa, cattle, palm oil, soya, rubber and wood;. They are listed in the Annex I of the EUDR.

Which product groups are affected?

  • Products impacted by the EUDR are coffee, cocoa, cattle, palm oil, soya, rubber and wood
  • The  number of derived products which fall under the scope of the Regulation are listed in the Annexe I of the EUDR. Those relate to amongst others but not limited to, leather goods, tyres, seals, chocolate, roasted coffee, glycerine, soybean oil, plywood, furniture and various paper and print products

Learn more about the EUDR

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Our services

With the deadline fast approaching, there is an urgent need to prioritise compliance, ensuring that your systems and procedures are effectively aligned to satisfy the requirements of the EUDR. 

We have the expertise and solutions to assist your EUDR compliance journey, both in the short and long term.

Supply chain mapping and identifying requirements

We assist in mapping your position on the EUDR map by connecting commodities and products with relevant legal entities and mapping the value chain up to the required level. Additionally, we identify the EUDR requirements for each legal entity specific to your commodities and products.

EUDR Compliance Assessment

We provide a thorough analysis of your specific EUDR situation and obligations related to your products and commodities intended for the EU market. This assessment helps you understand the steps needed to ensure compliance with EUDR.

Data analysis and gap identification

We have the right solutions to analyse your existing data and identify any gaps in data, processes and other capabilities that must be addressed to fulfil compliance and risk management requirements.

Strategy development

We work together with you to develop short-term and mid-term strategies and scenarios to ensure EUDR compliance across various areas including changes in procurement procedures, key performance indicators (KPIs), and exploring opportunities for resource-saving and technology-based approaches.

Implementation support and management systems

We provide assistance in implementing and constructing your compliance framework, identifying suitable tools and opportunities for cooperation.

Get to know our team

Our services are designed to address the time-sensitive nature of EUDR compliance, ensuring a prompt start to meet the necessary obligations up to a successful outcome for your business.

In the long term, the focus will be on improving compliance management performance and minimising compliance costs, whilst guaranteeing full compliance. Within a collaborative setting, this creates economies of scale, realises overall sustainable development goals (SDGs) and fosters competitive advantage and resilient markets for all stakeholders.

As such, we are collaborating with other solution providers to develop a cross- industry control tower approach to achieve this objective. Our approach goes beyond EUDR and the European market, encompassing other regulatory obligations and markets that our clients seek to access, whether as a farmer, grower, trader or operator.

How can PwC support your compliance efforts?

Trade, Customs and Legal Compliance

Challenge

Navigating the legal and customs requirements for palm oil supply requires adherence to various national laws of the country of production as well as international customs requirements and the legal documentation required for cross-border transactions.

How PwC can help

PwC provides specialized legal and customs compliance consulting. This includes assistance with legal obligations and documentation and ensuring that all trade activities are compliant with both local and international laws.

Limited Data and Information Sharing

Challenge

Obtaining reliable and accurate data from all stakeholders is crucial but challenging. Each participant in the supply chain often tracks only their segment using their own data logging system, leading to fragmented information. Farmers see little value in maintaining documentation without a price premium, and some importers withhold information, resulting in incomplete and inaccurate data for roasters.

How PwC can help

PwC can assist by developing integrated data management systems that facilitate seamless information sharing among all supply chain participants. PwC's data analytics and advisory services can help establish standardized documentation practices and incentives for accurate data collection and sharing.

Traceability and Supply Chain Complexity

Challenge

The fragmented and complex nature of the palm oil supply chain makes it challenging to trace products back to their origins and ensure sustainable practices.

How PwC can help

PwC offers advanced supply chain mapping and traceability solutions. We help companies track deforestation and forest degradation trends and monitor supply chain risks in near real-time, facilitating better decision-making and compliance.​

Regulatory Compliance and Reporting

Challenge

Complying with the EUDR's stringent regulations involves extensive documentation, monitoring, and reporting requirements, which can be burdensome for companies of all sizes.

How PwC can help

PwC can offer compliance advisory services to help companies understand and meet EUDR requirements. This includes developing comprehensive compliance strategies, assisting in the preparation of due diligence statements, and implementing robust monitoring and reporting systems.

What are the consequences of non compliance?

In case of non compliance, the commodities and products covered by the Regulation can no longer be placed on the market. 

Companies are also subject to massive financial risks through:

  • compulsory fines and penalties

  • temporary ban on the placing on the market, trade or export of relevant commodities or products 

  • temporary exclusion from public procurement

  • reimbursement of the authorities’ financial expenses

Frequently asked questions

Many companies are directly and indirectly impacted by the EUDR across a whole range of industries given the broad utilisation of several commodities. In Belgium, the number is estimated to be around 5000 companies. 

Distinction is made between Operators (SME and non-SME) and Traders. Depending where you land, the timeline and specific obligations differ: 

  • Operators are any natural or legal person who, in the course of a commercial activity makes the relevant commodity or relevant product first available on the Union market 
  • Traders are any natural or legal person in the supply chain other than the operator who, in the course of a commercial activity whether in return for payment or free of charge, supplies a relevant product for distribution, consumption or use on the Union market
  • Large traders, which are not small and medium-sized undertakings, are subject to the same obligations as large downstream operators. This includes any large company that is not an operator but commercialises products listed in Annex I on the Union market, such as large supermarket or retail chains. Their obligations include filing a due diligence statement, checking the due diligence previously conducted in the supply chain, and being held liable for any regulation breaches.

Non-SME operators and traders have until 29 December 2024, to review their (global) supply chains and implement the due diligence obligations required by the EUDR. 

An extended deadline to 30 June 2025, applies to SME operators.

The European Commission, as well as the competent authorities in the various Member States have been explicit that “non compliant” remaining inventory at the end of 2024, cannot be put on the market anymore as from 30 December 2024 by non-SME Operators and Traders.

This implies that remaining stocks of commodities and products will have to leave the market before the end of 29 December 2024. If not, the penalties as referred to in the EUDR will apply. 

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Contact us

Giovanni Gijsels

Giovanni Gijsels

Partner, PwC Belgium

Christoph Vanderstricht

Christoph Vanderstricht

rbr Expert Circular Economy & Sustainable Value Chains | Strategy & Transformation, PwC Belgium

Tel: +32 477 61 92 52

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