Due to the potential implications for trade in agricultural goods, New Zealand wishes to raise again the EU Deforestation Regulation (‘regulation’). New Zealand thanks the European Union for their response to AG-IMS ID 108157. However, we are still seeking clarity on several aspects of the regulation. New Zealand appreciates the opportunity to continue to engage with the EU in the Committee on Agriculture.
Like many others, New Zealand shares the EU’s desire to address global deforestation, and to halt and reverse global forest loss.
However, we are deeply concerned about the significant impact that the implementation of this regulation will have on global trade, and the high compliance burden it places on countries and producers whose systems are not linked to deforestation.
It is our firm view that this is not the most trade facilitative approach to achieve the objective of protecting global forests.
We are further concerned about the wide range of outstanding questions and issues that need to be addressed before implementation that limit the ability for suppliers and operators to prepare, including legal clarity around definitions, the operation of information systems and competent authorities’ processes. We also note the delay to the release of the next set of FAQs, guidelines and to the country benchmarking assessment process.
Furthermore, we hold a systemic concern about the prescriptive nature of the measure and the disregard for local conditions of production. New Zealand believes that a more effective approach would involve WTO members working together collectively, rather than contributing to the proliferation of unilateral initiatives which cause trade disruption and risk fragmenting the international trading system.
On this basis, we seek further information on:
a. Whether the EU will delay the implementation of the regulation past 30 December 2024 given we still do not have certainty on many essential parts of the Regulation, to give time to address stakeholders’ concerns and to ensure systems are able to comply with the regulation?
b. Whether the EU has further considered the need to prevent the imposition of undue barriers to trade for countries with strong forest management credentials?
We also encourage the EU to consider how it could advance dialogue multilaterally on trade responses to environmental challenges.