The EU Deforestation Regulation (EUDR)

The EU Deforestation Regulation (EUDR), which will replace the current EU Timber Regulation (EUTR), is now expected to come into effect on 30th December 2025

Though it should be noted that this proposed delay has not yet been ratified, and until that happens, the EUDR is still scheduled to begin on 30 December 2024.

This regulation significantly increases the data gathering and due diligence requirements for all businesses involved in supply chains connected with the EU. The UK timber industry is deeply concerned about the potential disruptions the EUDR may cause to the UK timber trade, particularly in the context of the potential disruption of trade between Great Britain (GB) and Northern Ireland (NI), the impact on the UK Timber Regulation (UKTR) implementation, and the short timeline given for businesses to prepare.

To mitigate these challenges, we are urging the UK government to provide clear guidance and consider regulatory alignment between the UKTR and EUDR, and advocate for a delay in the EUDR’s implementation.

Since the establishment of the EUTR in 2013, the UK has led the fight against illegal logging. Post-Brexit, the UK maintained this commitment through the UK Timber Regulation (UKTR), which will continue to be in effect in Great Britain (GB). However, the introduction of the EUDR presents significant challenges for UK businesses that need urgent attention and support from the UK government.

Lack of clarification on the status of Northern Ireland

GB timber buyers are currently governed by the UKTR, while wood buyers in NI remain subject to the EUTR. Although these regulations are practically and legally identical, uncertainty looms over what will happen after the UDR comes into effect.

Theoretically there should be no change, as the Windsor Framework promises unconditional and unfettered trade throughout the UK. However, the UK government has to date provided no indication of what, if any, additional requirements will apply in NI.

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For timber businesses the situation is particularly challenging. While timber companies have already incurred significant costs in order to comply with both the EU and UK timber regulations, they now face the additional burden of implementing a possible new legislative system to continue existing business operations with companies in NI.

Furthermore, no equivalent legislation in GB is comparable to the EUDR. This poses a significant challenge for GB suppliers, who must acquire and pass on the necessary information to their NI clients to meet EUDR requirements. The absence of such legislation in GB could result in reduced or even ceased trade between GB and NI, disrupting the flow of goods and negatively impacting businesses in both regions.

If the EUDR is introduced in NI without adequate government support and equivalent regulations in GB it will have an adverse effect, potentially leading to a significant decline in trade between the two regions.

TDUK believes the UK government must provide clear guidance well in advance of any changes to ensure businesses in both GB and NI have sufficient time to prepare. If the EUDR is implemented in NI, the government must offer strong support to facilitate a smooth transition and prevent competitive disadvantages. This includes raising awareness and providing the necessary resources for companies to meet the additional compliance requirements. Without this support, businesses – especially those in GB exporting to NI – risk facing higher costs, delays, and potential loss of market access.

It is also crucial to acknowledge that while the timber sector is one of the few commodity sectors subject to mandatory due diligence requirements, deforestation is primarily caused by the expansion of agricultural output. Commodities such as soy, palm oil, cattle and cocoa – all listed under the EUDR – are major contributors to deforestation. To our knowledge, none of these commodities currently operates a due diligence system at all, and none is ready for the requirements of the EUDR.

If the UK government is serious about implementing the EUDR in NI, it should focus on those agri-commodity supply chains that need significant improvement, rather than imposing additional obligations on the timber sector, which is already well-regulated and has robust due diligence procedures in place.

EUDR’s impact on the UKTR

The UKTR, implemented in 2021 after Brexit, will remain in place for all wood products on the GB market for the foreseeable future. UKTR requires UK timber importers to conduct due diligence on timber imports from the EU. With more than 80% of UK timber directly imported from the EU, primarily from low-risk countries like Sweden, the introduction of UKTR has added significant costs and burdens to UK companies – costs that were not intended when the EUTR was first introduced over a decade ago.

This additional workload and cost has already placed UK businesses at a competitive disadvantage compared to their EU counterparts. The introduction of the EUDR raises concerns that UK businesses will face even greater challenges in obtaining the necessary evidence from EU suppliers to comply with UKTR. This would be considered as double and unnecessary work, particularly given that the EUDR is stricter in scope and requirements than the UKTR. A specific concern is the sharing of GPS coordinates from EU suppliers with UK clients, which may need to be passed on to downstream clients who could re-export the products back to the EU.

TDUK is calling on the UK government to acknowledge the significant challenges that UK businesses face in conducting due diligence for timber imports from low-risk EU countries under the UKTR. We strongly urge the UK government to consider recognising compliance with the EUDR as equivalent to compliance with the UKTR to foster smoother trade relations between the UK and the EU, ensuring that UK businesses remain competitive in a global market.

Inadequate time to prepare

With its original schedule, the EUDR imposed a shorter implementation timeframe than any other comparable European legislation affecting industrial sectors. Additionally, there is a noticeable lack of awareness among EU companies about this upcoming legislation, and the EU has also delayed the release of essential supporting tools and implementation guidance for the EUDR. Therefore, it is of utmost importance that the proposed delay in the entry into application of the EUDR is granted.

TDUK is working with our partner trade associations in Europe, including CEI Bois, to urgently advocate for a delay in the EUDR’s implementation and allow businesses adequate time to prepare and comply. We would ask for the UK Governments assistance in emphasising to the EU commission that UK Exporters have not had sufficient time or the information necessary to build robust EUDR processes. Additionally, we would urge UK Government to enhance its efforts to raise awareness among UK companies to ensure they are prepared for this regulation.

Finally, we ask that UK Government works in closer partnership with the EU Commission to understand the complexity of timber supply chains between the EU and the UK to develop due diligence processes which allow wood products to flow seamlessly across EU/UK borders without a significant duplication of effort.

Source TDUK

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