Input for draft delegated regulation & annex amending Regulation (EU) 2023/1115

Introduction
We welcome the development of a delegated act to provide additional simplification, clarity and legal certainty to guide preparation for application of the EUDR in December 2026. In this paper, we provide our views on the draft version published for feedback on the Commission’s Have Your Say website. In commenting on the proposed draft, we ask not to further expand the scope at this stage to allow initial experience of its application with the current already broad range of products, many of which are traded in the retail and wholesale sector. In case that, based on the feedback received, the scope is extended, an additional transition period of 12 months for these newly added products is required and should be specified as part of the delegated act.

Key issues
• Delayed application for new CN codes
• Reliance on existing Due Diligence Statements (DDS)
• Support for proposed changes regarding waste, used products and secondhand products
• Support to the exclusion of Samples of products
• Support for the exclusion of bamboo, rattan and other materials of woody nature
• Support to specification for paper and paperboard
• Reject: Inclusion of Soaps (HS code 3401 11 00)
• To ADD: Explicit exclusion of Products for internal company use
• To ADD: Exclusion of ex 1602 50 - Other prepared or preserved meat, meat offal, blood, of cattle
• To ADD: Exclusion of imported packaging used to substitute deteriorated ones (ex 48)
• To ADD: Explicit exclusion of meals for direct consumption
• To ADD: Explicit exclusion of Donated products and charities

Please read the full Position paper below.