EUDR information system not yet on track to meet requirements of properly functioning supply chains

Dear President von der Leyen, 

We, the undersigned organisations, are supporting our member companies in their  commitment and need for a successful implementation of the EU Deforestation  Regulation (EUDR), which requires significant adjustments and efforts from  suppliers, operators and traders, throughout each supply chain of the commodities 

and products in scope, to effectively meet EUDR obligations. We support the  objectives of the EUDR and, in that spirit, we continue to offer constructive feedback  in the development of the EUDR Information System. 

The companies that participated in the pilot testing of the initial version of the EUDR  Information System (Register) in January this year, provided significant feedback  related to numerous gaps that needed to be addressed. They listed the  requirements for a fully functional system to DG ENV services, echoed by the  undersigned organisations on many occasions.  

The importance of the EUDR implementation challenge, the urgency of the matter,  given the implementation timeline, and the impact that an inoperable Information  System will have for the EUDR, leads us to bring this to your attention.  

During the last deforestation platform meeting of 24 April, we have not been  reassured that the Information System once revised by the Commission will be  meeting business needs. The technical specifications of the Information System and  the timeline for making it accessible to all operators and traders still raises serious  concerns. Requirements that are critical for the functioning of business supply  chains have been disregarded, notably the need for bulk commodities to handle  large volumes of data and for taking into account already used standard formats in  which data is being collected for traceability purposes.  

We, the undersigned organisations, call for: 

1. Planning a second round of testing with the business community  The list of inaccuracies and errors reported to DG Environment at the  outcome of the pilot testing was considerable. These issues, further to built in limitations of the system, such as the 72-hour time window for amending due diligence statements and the lack of automation, raised justified doubts  within the business community that all problems will be resolved in one  updated version. If these issues have indeed been solved, a second round of  pilot testing and/or a continuous testing group should provide companies  with much needed assurances. A dedicated stress test allowing companies  to upload large amounts of geolocalisation data would also be needed. 

2. Making the API specifications ready as of May for business to prepare We welcome the fact that following industry feedback, an Application  Programming Interface (API) is now being developed to ensure connectivity  between our companies’ IT systems and the Information System itself. We  would like to stress that our companies will need to significantly revamp their  IT systems to connect with the API – a process that takes few months and  can only be achieved if the API specifications provide precise information  regarding purpose, type, endpoints, HTTP methods, data formats,  parameters, authentication and security of the API.  

3. Lifting the 25MB limitation or substantially increasing file size for  uploading files as part of the due diligence statement 

For bulk commodities and liquids, but also for derived products, the  envisaged 25MB data limit, which represents about 1 million data points, is  insufficient as this number is likely to be reached within few weeks of  cumulated geolocation data from polygons. Several of our commodities are  cumulatively sourced from hundreds of thousands of smallholder farmers. In  addition, polygons are the preferred method to indicate the area of  production of goods, due to their higher accuracy compared to single  geolocation points. Combining the large number of suppliers with the large  amount of data points contained within each polygon, it is easy to reach the  threshold of one million data points contained in a 25MB file within a couple  of cumulated shipments. 

4. Accepting other data formats than the only GeoJson standard Pre-existing work on traceability has been built using different data formats.  Less than 8 months before application, limiting transferable format standards  to one (GeoJson) disregards the extensive work that has been done and rolls  over the burden to operators instead of providing workable IT solutions. The  ability to use additional data formats, which as industry representatives we  were asked to provide in June 2023, should be allowed. 

5. Opening up the information system for all users as soon as possible  and, at the very latest, beginning of November 

The current timeline to make the Information System available for general  use as of mid-December only, is totally underestimating the reality of supply  chains, as most harvests, from Autumn onwards, may only arrive in the  European Union after the date of application and would then require an  accompanying due diligence statement. A time period of merely two weeks  is insufficient for companies to create all these statements. In addition,  hands-on time is needed for all handlers, outside of training context to 

familiarise themselves with this new environment, ensure connection with  their own data management system and train appropriately relevant staff.

We have informed the Commission services in charge about the challenges of an Information System that would not be up to business requirements and standards  for EU supplies in all key commodities and for all relevant products in scope. We  would like to reemphasise this as well as to highlight the negative impact this would  have for the European Commission’s reputation both within the EU and with third  countries, not to mention consequences on the access to key supplies, including food, and on the competitiveness of EU supply chain actors.  

At the same time, we have expressed our clear willingness to offer IT expertise and  engage in a structured dialogue with a view to improving the System. We urge the  European Commission to make the Information System and the API rapidly adapted  to business needs. This central element of the regulation is critical for the successful 

application of the EUDR and we are increasingly concerned that it might become its Achilles heel. 

We are available to discuss these points with you in further detail.  Yours faithfully, 

The undersigned associations  

Bioenergy Europe – the voice of European Bioenergy 

CAOBISCO – Chocolate, Biscuit and Confectionery of Europe 

CEPI – Confederation of European Paper Industries 

COCERAL – European association of trade in cereals, oilseeds, rice, pulses, olive  oil, oils and fats, animal feed and agrosupply 

COTANCE – European Leather Industry 

ECA – European Cocoa Association 

ECF – European Coffee Federation 

ETRMA – European Tyre & Rubber Manufacturers Association 

Eurocommerce – the voice of Retail and Wholesale in Europe 

EUSTAFOR – European State Forest Association 

FEDIOL – EU Vegetable Oil and Proteinmeal Industry 

FEFAC – European Feed Manufacturers’ Federation 

FoodDrinkEurope – European Food and Drink Industry 

Copy is sent to Executive Vice-President Sefcovic, Vice-President Dombrovskis,  Commissioner Wojciechowski, Commissioner Breton, Commissioner Sinkevicius 

Signatories of the letter to President Von der Leyen – The EUDR information system is  not yet on track to meet requirements of properly functioning supply chains

You can download the letter at this link.