A call to ‘Stop the Clock’ and ensure a workable EU Deforestation Regulation
The signatories of this open statement recall that the effectiveness of any legislative framework depends on its practicality, legal clarity, and predictability. The recent amendments proposed by the European Commission to the EU Deforestation Regulation (EUDR), following the announcement of a further postponement, prolong a situation of costly uncertainty and unrealistic implementation timelines. The new proposal, coupled with the extremely tight schedule for its approval, risks undermining both the credibility and the effective enforcement of the Regulation, while placing European operators in an untenable position of legal and operational ambiguity.
The changes introduced by the Commission are substantial and deserve sufficient time for thorough analysis and discussion by stakeholders, policymakers, and Member States. This is exceptionally challenging given the current deadline of 30 December 2025. It is both unrealistic and unacceptable to expect companies to comply immediately with a regulation that has been hastily renegotiated only weeks before its entry into force. In practice, most large downstream industries will be unable to once again adapt their IT systems, which have been designed to interact with the TRACES platform, while small and micro downstream operators will face a significant increase in the number of DDS reference numbers accumulating along the value chain. Downstream operators of all sizes will therefore face compliance challenges with the new rules, which, at best, will be adopted only days before their implementation.
Moreover, the proposal fails to reflect the operational realities of the market, where medium-sized and large companies routinely work with small and micro-enterprises within integrated supply chains. Consequently, establishing different application dates – with large and medium-sized companies required to comply from 30 December 2025, and small and micro-enterprises granted twelve additional months – will, in practice, force all operators to comply from the same date. The interdependence of companies across the value chain renders the proposed delay ineffective, as smaller operators will have to align immediately in order to maintain their business relationships.
The sectors concerned continue to face a serious lack of clarity and legal certainty, which conflicts with fundamental rights guaranteed under EU law and remains indispensable for sound business operations, competitiveness, and investment.
The signatories therefore urge the European Commission to introduce a “stop-the-clock” mechanism, allowing policymakers to conduct a proper and comprehensive assessment of the Regulation’s impact and implementation. Such a reassessment should identify genuine simplification measures and make the EUDR obligations truly workable, while fully preserving the Regulation’s legitimate environmental objective of combating deforestation – a goal strongly supported by all signatories of this open statement.
