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COA Meeting start date 25/09/2024
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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.
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Answer Full Text
 a. The EU Deforestation Regulation (EUDR) is set to enter into application on 30 December 2024. Any postponement would require a legislative change. This would not achieve our goal to provide legal predictability for operators as soon as possible. The EU is therefore focusing on ensuring that all the elements necessary for the implementation of the Regulation are ready on time, including the guidance for economic operators and Member States, and the IT system.

b. Deforestation continues at an alarming rate worldwide. We have a shared objective to halt it by 2030. The objectives pursued by the EUDR are the internationally recognized, public policy concerns: the protection of the environment, the fight against climate change and biodiversity loss. The EUDR is intended to help fight climate change and biodiversity loss linked to global deforestation by addressing the role of EU consumption. The EUDR was developed in compliance with EU’s international commitments, including our trade agreements, and WTO requirements. It is designed to apply in an even-handed and non-discriminatory manner, i.e. to the most relevant commodities and products produced inside as well as outside the EU. It is not a trade ban: no country or commodity will be banned.  The traceability requirement through geolocation is at the heart of the regulation and applies to all shipments, imported into the EU and exported from the EU. Strong forest management credentials cannot entail full derogation from basic requirements as this would make circumvention too easy. Especially where supply chains are long, complex and involving many countries. The measure adopted is supported by solid evidence as spelled out in the Commission Impact Assessment

We are committed to implementing the Deforestation Regulation in a spirit of close partnership, transparency, and open dialogue and will continue our positive engagement. Our ultimate objective is to ensure effective implementation of this environmental measure without undue trade disruptions.
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Importing Members' food security
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Quantity and concessionality of food aid
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All agricultural products
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Question Summary
EU’s Deforestation and Forest Degradation Strategy
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