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Huge bureaucratic burdens for the agri-food sector in the face of EU regulation about deforestation-free supply chains

Lack of state preparedness impedes implementation in accordance with the law and risks a false start.



The EU Deforestation-Free Supply Chain Regulation (EUDR) is deemed largely unenforceable by the agriculture and food industry twelve months before its planned start. There is no concrete list of information that must be submitted, nor is there a sophisticated computer system for the millions of data records required for verification. There is also a long way to go to achieve the necessary state cooperation with important countries of origin. Because the European Commission has not yet been able to clarify almost all key implementation issues, the economy risks running out of time to implement the new provisions in practice. Many German agricultural and food associations express this fear.

The regulation is in force from June 29, 2023. As of December 30, 2024, millions of producers and traders around the world of coffee, cocoa, soybeans, palm oil, livestock, hides and skins, wood and rubber will have to provide extensive evidence that their products come from deforestation-free areas if they continue to sell them on the EU market and want to sell them. This involves a lot of bureaucratic effort. For example, as a result of the regulation, according to calculations by the German Coffee Association, a typical medium-sized green coffee importer or roaster will have one person working full time for about three months a year simply uploading data to the German Coffee Association's database. EUDR or by entering them manually. Politicians constantly talk about digitalization, but associations complain that they require companies to manually enter millions of mandatory data into PCs every year.

The regulation also applies to producers in Europe. “The forester in the Black Forest, the soybean producer in the Danube and the livestock farmer in northern Germany should also be exposed to significant bureaucratic demands. However, for Germany and much of Europe, the “deforestation problem” is sufficiently documented and practically non-existent. From our point of view, it is even more incomprehensible that such a bureaucratic information and control system is established that imposes on each producer an individual registration requirement with an extensive declaration system. This path counteracts any political declaration about reducing bureaucracy,” said Bernhard Krüsken, general secretary of the German Farmers Association (DBV).

The meat industry is also alarmed: "We also need a practical solution for the European beef production chain that does not place any additional burden on our domestic animal farmers and downstream, and focuses on what is essential," says Steffen Reiter, general director of the Meat Industry Association (VDF).

In Germany alone, hundreds of thousands of large and small companies have to adapt their merchandise and supply chain management systems to the additional documentation requirements. Large investments and organizational changes are required to prepare for its implementation in companies. Without clear knowledge of the exact requirements of the authorities, these cannot move forward. Time is running out for those involved.

"As long as the EU Commission and national authorities cannot guarantee practical testing for companies, the existing transition period must be extended to avoid empty shelves," said Carsten Bernoth, CEO of the Federal Association of the German Confectionery Industry.

“In particular, many small and medium-sized companies in the sector find it difficult to cope with increased bureaucratic burdens. For this to work, there needs to be clear and practical guidelines for its implementation in companies, as well as enough time to prepare for the additional requirements. The EUDR still lacks both,” says Olivier Kölsch, CEO of the Federal Association of the German Food Industry (BVE).

The legally secure application of the regulation from the end of 2024 can only be achieved if the European Commission finally quickly removes crucial technical and administrative obstacles. German industry associations are calling on the German federal government and the European Commission to avoid the "imminent fiasco." The validity of the regulation should be postponed until the crucial issues for each product are clarified, so that all those affected can begin to apply it in a legally secure manner.

The implementation of the EUDR is also the focus of an expert panel that the Grain Club alliance of associations ( will hold within the framework of the Global Forum for Food and Agriculture (GFFA) on January 18th in Berlin.

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