WHAT IS A ‘…FOREST…’? YOU’D THINK WE WOULD ALL KNOW WHAT A FOREST LOOKS LIKE…’
These are just some of the obstacles in the way of EUDR…or whatever eventually comes out of the EU. Before I look at some of the features of a new guidance document, it is worth mentioning that there have been losses already incurred by this very action of delaying EUDR. FEDIOL, the EU’s vegoil & oilmeal association said its members, including some of the trading giants and food processors, will suffer from the delay after paying premiums for EUDR compliant raw materials. Elsewhere, cocoa processors & chocolate makers face a similar scenario with traders paying up to 6% or approximately GBP 300 per Mt premium for EUDR complaint beans. This premium is now set to disappear as it would be hard to pass onto consumers a premium from a law that has been pushed back4
. Finally, reduction of 3.3% in public
revenue FEFAC – the EU animal feed industry body estimated EUDR compliant soybeans would cost an additional 5 – 10%. However, it should be noted that FEFAC were also a co-signatory to a Joint Statement urging a delay to EUDR5
.
Let’s now look at some of the features of a new guidance document that has been released by the European Council to aid compliance with EUDR6 is not a complete review of the whole document7 but it will cover some of the main elements.
. This …
4
reuters.com – 8 Oct 2024 5
fefac.eu – 25 Sep 2024 6
feednavigator.com – 7 Oct 2024 7
https://green-business.ec.europa.eu/document/down- load/162138c8-7c22-4bb5-98ce-fd31c81d6936_en?file- name=C_2024_7027_1_EN_Guidance%20on%20EU%20 Deforestation%20Regulation%20.pdf
WHAT IS A ‘…FOREST…’? You’d think we would all know what a forest looks like, but there is now definitive explanation of what one is. It is an area of trees (I haven’t dug deep enough to see if there is a definition of ‘trees’ yet) that is more than half a hectare in size, with canopy cover of more than 10% and trees reaching an average height of 5+ metres. This regulation also applies to an area where the trees are able to reach these conditions but have not matured enough to do so at this time.
WHAT IS AN OPERATOR? In EUDR, this is a natural or legal person who places the relevant commodities on the market, making them available on the market for the first time, all as part of commercial activity. Inside the EU, these are producers, manufacturers and exporters, outside the EU these are importers, independent of who owns the actual products. An Operator is one who is placing a commodity or product on the EU market for the first time, a keen and subtle point. In other situations where a commodity or product is made available to the market, the entity doing so is a Trader. A Trader is an entity other than an Operator, who makes products and commodities available on the market, in the course of commercial activity. An important fine point is that an entity is an Operator if they are placing a commodity OR a product…so that an importer of cocoa beans into the EU and a manufacturer making and selling chocolate bars… would both be Operators.
10 | ADMISI - The Ghost In The Machine | Q4 Edition 2024
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