Programme for the Endorsement of Forest Certification

PEFC is the world's largest forest certification organisation

Now is the Time for EUDR Preparation

Posted on June 26, 2024

With the EUDR soon to enter into force, Maggie FitzHerbert, Senior Responsible Sourcing Manager at the Soil Association, gave the audience at the PEFC UK stakeholder day in Edinburgh, 23 April, some reminders that now is the time to become better prepared for its introduction and PEFC can help.

Published in June 2023 with an 18-month implementation period, the EU Deforestation Regulation (EUDR) and its full requirements will come into force on 30th December 2024, when businesses within the EU or supplying into the EU or Northern Ireland must ensure the timber and wood-based products they trade in are legally and sustainably sourced and are verifiably deforestation and degradation-free.

For those in the timber industry, this means verifying that their products – sawn timber, wood-based materials, paper and furniture – do not originate from land deforested or degraded after 31st December 2020, and that they comply with the environmental and social laws of the specific country of production. This will include pursuing a thorough due diligence process, tracking the entire supply chain and providing data that demonstrates compliance with the EUDR.  The level of due diligence required in a country will depend on the risk category (‘low’, ‘standard’ or ‘high’) assigned to it by the EU. Currently, all countries, including the UK are categorised as ‘Standard’ risk so a full due diligence system (DDS) is required.  Penalty fees for non-compliance will be severe and include fines of 4% of annual turnover, with products potentially seized and prohibited from entering the EU market.

The EUDR builds upon the EU Timber Regulation (EUTR) but extends its reach to a broader array of commodities – cattle, cocoa, coffee, oil palm, rubber, soya, wood – and products derived from these commodities, to reduce the EU’s impact on global deforestation, climate change and biodiversity loss, and enhance its commitment to sustainability.

Why does this affect UK businesses?
UK businesses with operations in the EU, or customers within the EU, need to have a comprehensive understanding of their supply chains. As the 30th December 2024 implementation date approaches, businesses must take proactive steps to ensure compliance by implementing robust due diligence systems, engaging with stakeholders, training staff and staying informed about updates or changes to the EUDR and related regulations.

Within the EUDR there are also new definitions of timber ‘operators’ and ‘traders’ so compliance may require significant adjustments to existing supply chain management practices with additional costs related to verification and documentation.  New demands on UK companies will include them having to share geolocation data and harvest dates of their wood-based products to allow EU customers to comply with the EUDR, so UK companies will receive data requests on their product origins. Within Northern Ireland, the EUDR may be applied under the NI Protocol, but Defra and the European Commission have not made a statement about its application yet.

What should UK companies be doing now?
Everyone trading and processing timber must understand their exposure to the EUDR. This means knowing whether products you trade are in scope of the EUDR and could end up on the EU market further down the supply chain. You should review and revise your company procedures and policies to make sure that your operational activities, risk assessments, due diligence and traceability systems are up to date.  This may require educating, training and raising awareness throughout your organisation and employing additional resources if needed.

As things progress throughout 2024, it is important that you familiarise yourself with the EUDR and plan how your business will implement changes. It is essential to engage your suppliers to gather information such as harvest date and geolocation, as it is needed by companies trading in the EU.

PEFC and EUDR alignment
The EUDR is an evolving process with complex implications and can be challenging for stakeholders. PEFC offers a clear pathway to EUDR alignment and is committed to adapting its sustainable forest management (SFM) and chain of custody requirements to align with the EUDR.

PEFC are proposing to fully align their SFM benchmark standard with the EUDR, thereby ensuring that over time all material certified under a PEFC SFM certificate will be EUDR compliant. Additionally, the new PEFC EUDR DDS module will make the EUDR framework understandable for PEFC chain of custody certificate holders to implement, benefitting from the synergies within PEFC’s existing requirements. The aim is to provide a system that is easily integrated within the current chain of custody processes, in a way that the organisation can take the module and implement it within a system they are already familiar with.

PEFC International has a regularly updated platform for EUDR information, compliance requirements and how PEFC certification will help. You can access it here