Introduction
On December 4, 2024, the EPICC research project (Environmental Policy Instruments across Commodity Chains) organised a Stakeholder Roundtable on the Implementation of the European Union Deforestation-Free Products Regulation (EUDR) to engage with the latest developments on the regulation. The roundtable happened just after the conclusion of the EUDR trilogue at the European level on December 3, where an agreement was reached on a one-year delay for the regulation’s entry into force and where other possible amendments, such as the creation of a ‘no risk’ category, were set aside.
The event brought together key actors who are participating in the discussions at the European level, including policy advisors from the Commission, producing countries delegations, and representatives of international civil society. The roundtable – organised under Chatham House rules – offered a valuable opportunity to exchange insights and to contribute to key aspects of the regulation’s implementation, but also to think about future collaborations between academics and non-academics, the need for sciences-based policies and the importance of coordinating more with EU Member States (MS) and non-State actors from producing countries.
This blog delves into the latest developments surrounding the new regulation and highlights key takeaways from the roundtable discussions. It aims to support ongoing research and policy initiatives on the EUDR, by fostering engagement not only among academics but also policy stakeholders and civil society. The blog concludes with reflections on future directions inspired both by the roundtable dialogue and the multidisciplinary work conducted within the scope of the EPICC research project.
For more information on the EUDR, you can explore our detailed blog, which offers insights into the key requirements, actors, processes, and implications of the regulation.
Socio-economic aspects are a blind spot of the EUDR
Some participants expressed concerns that the framework for cooperation with third countries proposed under the EUDR, including the Strategic Framework for Partnerships, fails to adequately address the regulation’s socio-economic consequences in the countries of production, and therefore may be detrimental to the commitments to both climate and social action. According to one participant, ensuring that smallholders earn a living income is a critical issue that current frameworks do not sufficiently address because it does not consider how the costs of adaptation will be distributed and does not impose any obligation on larger players to assume it (see more below). Future efforts should thus integrate the social components of global agri-food chains into environmental sustainability discussions.
One key point of discussions centered around the benchmarking exercise that will be done by the Commission before June 2025, classifying countries into ‘high’, ‘standard’ or ‘low’ risks. Almost all participants pointed out the unilateral nature of the exercise, and the pressure that the system would exert on producing countries. The benchmarking system would fail to differentiate between regions or producers within a country, potentially creating reputational damage and unfairly hampering market access for producers who are operating in riskier contexts. In other words, the business choices of traders and operators to avoid negotiating with ‘high-risk’ regions may have an impact on the totality of producers in a given region and face them with exclusion from the supply chain even if a significant parcel in that region did not contribute to deforestation.
Participants also highlighted that the EUDR’s focus on a handful of commodities does not do justice to the complex causes of deforestation, assuming that deforestation in any country would be necessarily linked to these commodity chains. As a result, producing countries are concerned with the need to divert funds from existing initiatives addressing the ‘real’ causes of local deforestation (e.g. mining or illicit activities) toward the creation of the geolocation and traceability systems in compliance with the EUDR.
Smallholders: a central concern amid calls for a broader impact assessment
Smallholders have been at the centre stage of discussions surrounding the EUDR. This issue has drawn significant attention in both academic and policy circles, reflecting widespread concern over the regulation’s implications for vulnerable actors in producer countries.
Several participants underscored the persistent lack of clarity and information about the EUDR’s implications for smallholders in producer countries, raising concerns about potential increases in production costs and the risk of restricted access to the EU market for these actors. That unclarity is unsurprising, considering that no formal impact assessment concerning smallholder farmers was conducted throughout the EUDR legislative process. The impact assessment is only planned to take place in 2028 (Art. 34.6). Furthermore, a key point raised during the discussions was the widespread lack of awareness about the existence of the regulation, let alone its consequences. This issue is, according to participants, compounded by the technological challenges faced by smallholders in regions with limited infrastructure, making it particularly difficult for them to meet georeferencing and traceability requirements.
Interestingly, several participants noted that while sufficient value is being generated within the commodity chain to cover the cost of compliance, smallholder producers will likely be disproportionately burdened. This argument is particularly compelling given the unequal distribution of power within the targeted commodity chains, which is often used by oligopolistic players to obtain better prices from providers and to charge higher prices to downstream actors and consumers. However, it seems that passing the costs to farmers is not inevitable. Cocoa was highlighted as a striking example: although a global shortage in supply and the speculative nature of the commodity led to a sharp rise in cocoa prices, traders and operators demonstrated a willingness to pay higher prices. The real question may be, therefore, not whether large traders can afford the premium required by the EUDR (spoiler alert: they can), but whether there is a willingness to pay it rather than shifting the financial burden onto the most vulnerable players in the value chain (i.e. small producers and consumers).
Partnerships, cooperation and dialogue in addressing deforestation
The cooperation with third countries and partnerships has been recognised under Article 30 of the EUDR as a key point for the achievement of the objectives of the regulation in addressing deforestation and forest degradation. This article specifically enshrines that the Commission (and interested EU member states) must engage in a coordinated approach with third countries in existing and future partnerships to address the root cause of deforestation. As informed during the roundtable, different programmes are currently being implemented by the Commission, of which the SAFE programme garnered most of the support from various EU countries since the adoption of the regulation. According to roundtable participants, the delay in the implementation of the EUDR specifically provides an opportunity to get more financing on board and scale up these existing partnerships and financial support.
The discussion also highlighted the difference between cooperation and partnership. While cooperation would involve cooperating towards the implementation of the EUDR, fostering partnership entails dialogue and working toward longer-term, shared goals such as tackling the root causes of deforestation, emphasising the need for collaboration that goes beyond mere regulatory compliance. For some participants at the roundtable, a true partnership would thus focus on mutual achievements in addressing deforestation, and should be built around the international principle of Common But Differentiated Responsibilities (CBDR). Not only with regard to future deforestation but also to previous erasure of forest in Europe and elsewhere. A central proposal to address this imbalance was the need to rethink the benchmarking system and its current methodology. Categorising countries as high-risk or low-risk was criticised for potentially oversimplifying complex realities and harming compliant producers within high-risk regions.
Concluding remarks
With several significant developments surrounding the EUDR in the weeks leading up to the roundtable, the roundtable served as a timely opportunity to review the past year’s efforts by the various stakeholders tasked with implementing the regulation.
Some key concluding insights were provided by participants, including:
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The EUDR is just one piece of a broader framework, requiring alignment with initiatives like the CSDDD, the CSRD, and the EU Taxonomy Regulation. However, the EUDR is particularly sensitive for producing countries and for organisations promoting global trade in agri-food, even for smallholders. Efforts to streamline compliance between the EUDR and the CSDDD (Corporate Sustainability Due Diligence Directive) were also underlined, including a unified helpdesk or “one-stop shop”. However, streamlining may lead to the complete watering down of the regulatory efforts.
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Comprehensive impact assessments are urgently needed to understand the legislation’s social and environmental effects along commodity chains, in particular in the case of small-scale producers and territories where deforestation is produced by multiple factors. Collaborative monitoring efforts involving EU and non-EU researchers and academics is essential to ensure clarity and support for vulnerable actors.
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Fostering partnerships would entail the need for collaboration between the EU and third countries that goes beyond mere demand for regulatory compliance and towards a comprehensive dialogue in addressing shared goals, including tackling the root causes of deforestation. However, partnership may also mean rethinking the uneven distribution of value between countries that supply raw materials and the EU that transform them into added value goods that are often re-exported.
As highlighted in our recent work on the EUDR, the current framework continues to be embedded in commodified food systems and intensive production models. To truly advance sustainable production in line with the SDGs, it is essential to rethink current production, distribution and consumption patterns, and redesign trade and policy frameworks so as to promote agri-food chains that respect both planetary and social boundaries. Global trade in agri-food can hardly be such a space. That is both because international trade cannot be a ‘level playing field’ unless the EU addresses its historical role in ecological breakdown resulting from the pursuit of intensive and cost-effective production systems in other territories, but also because of the inherent tension between liberalised trade, food security and nutrition, ecological integrity and stability of markets and livelihoods.