EUDR: EU feed industry concerns about growing risk of feed supply chain disruption

Dear President of the EU Farm Council, dear Mr. Clarinval,
FEFAC, representing the EU compound feed and premix industry, takes the liberty of
contacting you directly to express our members growing concern about the potential risk
of disruption of established trade patterns for the supply of essential Hi-Pro soy products
for the EU livestock sector which may result from the lack of clarity of key provisions of
the EUDR Regulation for feed chain operators and traders and in particular the absence
of a robust, “road-tested” Central Information System meeting business needs.
FEFAC members have noted with great interest the high-level discussions at the EU
Farm Council level in March and April 2024 on EUDR implementation impacts on EU
farming and forestry sectors. Many Member States called for a rapid revision of the
EUDR regulation, pointing to unresolved implementation challenges (IT system,
disproportionate administrative burden etc.) due to the current risk classification of EU
Member States resulting from the announced postponement of the EC’s country
benchmarking system.
We do recall our full support for the common objectives of the EU and COP28 to reduce
global deforestation and consider that as key supply chain partners for the EU livestock
sector, we have taken responsible, verifiable actions to secure our essential supplies for
“deforestation-free” soy and palm co-products together with our supply chain partners in
the EU and overseas, which should be recognized by the EU’s competent authorities.
As you are aware, FEFAC members have invested for many years in practical tools
based on FEFAC’s Soy Sourcing Guidelines which were first issued in 2015 and updated
again in 2023. They include 73 sustainability criteria covering good agricultural practices,
environmental protection (incl. “non-conversion” criterion), responsible working
conditions and land rights of indigenous people. Currently, there are more than 20
available soy certification/verification programs in the market, which have undergone
rigorous, independent benchmarking facilitated by the International Trade Centre (ITC)
in Geneva, published on FEFAC’s dedicated webpage on ITC Standards Map.
However, we need to draw your attention to the specific EU feed supply challenges linked
to a lack of clarity and legal certainty on current practical sectoral EUDR guidance for
operators and traders of soy and palm products destined for the feed sector, which
accounts for app. 30 Mio tons of soybean meal and app 1,5 Mio tons of palm products.

cc: EC President von der Leyen, EVP Dombrovskis, EVP Šefčovič, Commissioner
Wojciechowski and Commissioner Sinkevicius
This has led to a situation where our suppliers from a wide range of export countries do
not currently submit any market offers for soy and palm products for deliveries to the EU
after January 2025, prompting growing market concerns about potential trade disruption
and loss of market access which could trigger significant risk premiums for essential feed
ingredients with very limited market alternatives. This may cause significant adverse
economic impacts on EU livestock farmers, including loss of competitiveness due to
rising feed costs, while still recovering from the combined effects of the COVID crisis,
Animal diseases and the Russian aggression in Ukraine.
At this time of the year, our feed companies would normally sign forward contracts both
for deliveries of key feed ingredients but also for compound feed sales to EU livestock
farmers, many of whom sign contracts in advance for up to one year of feed use
coverage.
In its own sectoral Risk Assessment, FEFAC estimates that there is sufficient availability
of deforestation-free soy to cover market demand in Europe, both from home-grown and
imported origins. Most of the soy used in the EU originates from no-risk/ low-risk areas.
However, the absence of a robust central IT system meeting business needs and
inadequate practical sector-specific advice and guidance by the EC and competent
control authorities for operators are rapidly increasing the risk of potential EU feed supply
chain disruption. FEFAC already alerted the European Food Security Crisis
Preparedness Mechanism (EFSCM) on EUDR implementation challenges as an
emerging threat to the EU feed supply chain.
We would therefore urge you to consider a targeted list of measures at the EU Council

level, which could ensure continued market access of the EU feed sector to EUDR-
compliant soy and palm products, based on the very pertinent advice of EU Farm

Ministers and the EU Farm Commissioner, as well as respective EU agri-food chain
sector recommendations.
We believe that at this stage the EU needs to concentrate its efforts on key simplification
measures for the mandatory Due Diligence Statements, mainly linked to the new

traceability requirements based on geolocation data (for crops) by providing a “road-
tested” robust IT system, which meets business needs, as a matter of urgency. In this

context, we fully support calls by EU Farm Ministers and agri-food & forestry chain
partners to make use of existing, well-established traceability and certification systems
and best practice guidance by operators (as in the case of our FEFAC Soy sourcing
guidelines which require ISO standard based farm audits). We, therefore, recommend to
the Belgian EU Council Presidency to establish a realistic “phasing in” EUDR working
calendar with clear milestones, tackling the key traceability provisions and the respective
IT system as the “1st hurdle” for the EUDR implementation.
We do remain at your full disposal to provide any additional information on our EU feed
supply chain concerns and practical proposals on facilitating EUDR implementation to
maintain established trade patterns for the essential supply of soy and palm products for
feed use. FEFAC members will continue their efforts to diversify the feed supply chain
supporting more resilient, sustainable, and competitive EU livestock production systems.
Yours sincerely,

Pedro Cordero
FEFAC President

You can download the letter at this link.