Open Letter: Imminent feed sourcing challenges expected with entry into application of EU Deforestation Regulation
The undersigned organisations express deep concern about the expected adverse economic impacts and supply chain disruption risks to essential feed supplies for the EU livestock farming value chain resulting from the imminent implementation of the EUDR (EU Deforestation Regulation) on 30 December 2026.
Enforcement of the EUDR is foreseen in a period where the EU feed chain faces compounded, exceptional adverse impacts due to the summer drought in large areas of the EU, which sharply reduced availability of home-grown feed supplies (forages, maize and other oilseed crops and feed grains) as well as Black Sea trade disruption for grain exports. This exceptional situation can only be mitigated by increasing imports of feed materials, including high-fibre feed for the cattle sector and other small ruminants, as well as energy-rich crops (maize) and feed protein sources (soybean meal) for all livestock sectors.
As the EU livestock sector now needs urgent relief and targeted mitigation measures to facilitate access to alternative-sourced feed materials, the EUDR poses an additional challenge due to an estimated loss of market access to direct soybean meal imports and palm kernel expellers, exacerbating a ‘perfect storm’ scenario for the marketing year 2026/2027.
The compound feed manufacturing sector is experiencing this ‘imminent EUDR entry into application’ for the 3rd year in a row, following two earlier one-year postponements. Though feed industry market experts have indicated that anticipated EUDR risk premiums are expected to stabilise, the economic perspective has in fact strongly deteriorated due to the feed material sourcing shortfalls suffered because of the severe summer drought and Black Sea trade disruption.
The signatories fully support the objectives of the EUDR and acknowledge the importance of sustainable soy production. It is, however, unfortunate that the design of the EUDR has inherent constraints that make it incompatible with global commodity trading for soybean meal. It is important to note that there is no shortage of ‘deforestation-free soy’ available on the global market, due to the success and market acceptance of the FEFAC Soy Sourcing Guidelines, in place since 2015 and with over 20 soy certification schemes benchmarked by ITC (International Trade Center). However, EUDR compliance requires significant investments in logistics infrastructure demonstrating dedicated supply chains, which significantly reduces market availability of EUDR-compliant soybean meal deliveries to the EU from key export countries, despite heavy investments already having been made.
The signatories call on the European Commission to take exceptional measures to ensure feed security through a contingency plan, thereby preventing an economically unviable situation for the EU livestock sector in early 2027. There is an urgent need for targeted simplification of the EUDR as well as practical implementation measures, ensuring trade of ‘in-scope’ feed ingredients (soybean meal, palm kernel expeller, palm fatty acid distillates, cocoa hulls) is not further disrupted.
We recommend the EU consider additional trade facilitation instruments, setting up targeted bilateral agreements with key exporting countries for ‘in-scope’ feed materials to the EUDR, making use of existing and future EU trade agreements, as part of a necessary broader commodity-specific approach. It is also important to note that, if not addressed, the aforementioned issues faced by feed supplies will also have a significant impact on our already existing relations with third-country partners.
We express our utmost concern that the EUDR will negatively and disproportionately affect the competitiveness of EU livestock production, placing third-country exporters of finished animal products at an economic advantage by being able to benefit from feed materials not subject to EUDR-induced cost increases. This ‘self-inflicted wound’ runs counter to the EU Livestock Strategy objectives, as its adverse impact on market access for essential feed ingredients will reduce the competitiveness of our livestock farmers and the affordability of products of animal origin for EU consumers.
List of signatories:
AVEC – EU Poultry Meat Association
COPA-COGECA – European Farmers and Agri-Cooperatives
EDA – European Dairy Association
FEFAC – European Feed Manufacturers’ Federation
UECBV – European Livestock and Meat Trades Union