EUDR – EU trade letter to Commission ahead of April review
Recalling that the EU institutions agreed to carry out a simplification review of the EUDR legislation. The grain trade welcomed the reopening of the legislation. However, the Commission has interpreted this as concentrating on revising the delegated and implementing acts derived from the basic act, as well as updating the FAQs and guidance.
Sharing letter from Coceral, Fediol and Fefac on current discussions in relation to next steps with EUDR regulation ahead of review end April. The main call is for co legislators to consider the following aspects.
- Build a repertoire of relevant national legislation in all countries where products under the scope of the Regulation are produced and alternative types of evidence to prove legality of production. Operators cannot possibly gain an exhaustive knowledge of every regional and local legislation in all the exporting countries
- Ensure harmonisation of EU competent authorities controls and checks, through: o a binding guidance regulating and/or standardising the checks of the national competent authorities
a harmonised, risk-based approach by the competent authorities in assessing the risk of non-compliance.
- Harmonise Member States’ approach with regard to the management of data under ‘declaration in excess’ (200% silo capacity rule): the FAQs state that first‑in first‑out or similar systems are acceptable as long as no unknown‑origin or non‑compliant commodities are mixed. However, some competent authorities still require a 200% silo capacity rule. This needs to be clarified explicitly to ensure all authorities accept alternative compliant systems.
Letter is attached for your information only, not to be circulated.
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