Trase urges EU not to weaken deforestation-free commodity rules

The EU deforestation regulation (EUDR) aims to reduce Europe’s role in driving deforestation and human rights abuses in countries such as Brazil, Indonesia and Côte d’Ivoire by preventing companies importing or exporting commodities that have been illegally produced or grown on recently deforested land. The regulation came into force on 29 June 2023 and is due to take effect on 30 December 2025.

Since the European Parliamentary elections in June 2024, there have been growing calls to weaken environmental legislation including the EUDR. Implementation of the regulation has already been delayed by one year to allow additional time for regulated companies and member states to prepare. Despite this, some member states and businesses continue to demand further concessions.

From 22 July to 10 September 2025, the European Commission conducted a call for evidence to “simplify and streamline administrative requirements related to the environment in the areas of waste, products, and industrial emissions.” The Commission says the initiative aims to “reduce administrative burden without affecting the policy objectives pursued by the legislation.”

The consultation received 119,542 responses, the majority of which (97%) came from EU citizens. Companies and business associations submitted 853 responses, while 259 came from non-governmental organisations, environmental groups and research institutions, and 40 from public authorities. Trase’s submission advises the European Commission not to include the EUDR in its plans to simplify environmental legislation for the following reasons.

Undermine the EU’s environmental objectives

The EUDR is a central pillar of the EU’s longstanding plan to tackle deforestation and plays a vital role in meeting the EU’s environmental policy objectives as set out in the Green Deal and its international commitments on climate under the Paris Agreement and biodiversity under the Kunming-Montreal Global Biodiversity Framework.

Weakening the EUDR by introducing measures to “simplify and streamline” it would therefore undermine the EU’s policy objectives. In the run up to the COP30 climate summit in Brazil in November, this would signal to the world that the EU is no longer committed to addressing these challenges, undermining international efforts just when they are most needed.

Create regulatory uncertainty and undermine investments

Many companies and competent authorities are well-advanced and ready for implementation of the EUDR. Over 60 major companies including Nestlé, IKEA, Barry Callebaut, Unilever, Mars and Ferrero have publicly backed the EUDR and opposed efforts to weaken it. These companies have invested in compliance systems and warn that changes now would undermine these investments, deepen regulatory uncertainty and cause further delays.

Producer governments have also invested in supporting EUDR compliance including in national traceability systems, geolocation of smallholders and forest monitoring systems and maps. This includes Kenya’s and Cameroon’s coffee sector, Costa Rica’s timber sector, and Peru’s coffee and cocoa sector. Delaying or diminishing the EUDR would undermine the EU’s credibility and partnerships with producer countries.

The EUDR already minimises administrative effort

The EUDR uses an inherently risk-based approach for regulated companies to implement due diligence and competent authorities to deliver enforcement, and already includes many provisions to reduce administrative effort. This includes simplified due diligence for products produced in low-risk countries (Article 13), for small and medium sized operators (Article 4 (8)) and downstream companies (Article 4 (9)).

A recent study also highlighted the low cost of compliance which it estimated on average as 0.1% of companies’ annual revenues. Competent authorities have also undertaken many dry runs with companies that have delivered trial shipments of EUDR compliant commodities (e.g. palm oil, cocoa, soy) demonstrating that they are ready for implementation.

The EUDR (Article 34) already contains a provision for a general review of the regulation by 30 June 2028. The EU should wait until this opportunity to fully and properly assess the impact of the EUDR based on evidence of its effectiveness.

Proposals to simplify the EUDR are not feasible and would weaken its effectiveness

Recent proposals to simplify the EUDR such as a zero-risk category with no obligations for due diligence for products sourced from these countries would create significant loopholes in the EUDR and undermine its environmental objectives. A zero-risk category that does not require due diligence obligations including geolocations or enforcement checks could incentivise unscrupulous companies to launder commodities from higher risk locations through zero-risk countries.

Such a proposal has already been rejected by Member States last year and could also breach WTO rules. Once a commodity is processed in or simply rerouted through a no-risk country, its origin could be easily disguised. This issue has been documented for timber and the mislabelling of illegal Russian plywood by companies on customs documentation as Chinese, Kazakh or Turkish to disguise its origins and evade sanctions.

The European Commission is due to present its proposals before the end of 2025.

Trase response to the call for evidence on the simplification of administrative burdens in environmental legislation, September 2025