Coalition of Global Food & Commodity Companies Push EU to Keep EUDR on Schedule

Key Takeaways

• Coalition Position Companies and organizations across food, cocoa, coffee, palm oil, rubber and timber supply chains are calling for the EU Deforestation Regulation (EUDR) to proceed without delay, suspension, or a simplification review clause.
• Concerns About Uncertainty The group says proposals to pause the regulation would prolong legal and market uncertainty and undermine investments already made by companies preparing for compliance.
• Delay Opposition A one-year delay is opposed on the grounds that it would recreate the uncertainty observed in 2024 and 2025 and would not ensure IT systems or authorities are fully ready by 2026.
• Grace Period Proposal The coalition supports a six- to twelve-month grace period during which companies file required information but authorities would not impose penalties, allowing systems to stabilize.
• Traceability and Due Diligence The coalition views supply-chain traceability as essential and proposes an alternative streamlined system for submitting due diligence statements and maintaining records.

Deep Dive

A coalition of companies, non-governmental organizations, and multi-stakeholder groups from the food, cocoa, coffee, palm oil, rubber and timber sectors is calling on the European Commission to proceed with the EU Deforestation Regulation (EUDR) as scheduled. The group is reiterating its position that there should be no “stop-the-clock” mechanism, simplification review clause, or one-year delay to the regulation’s implementation.

The coalition argues that proposals to suspend the regulation through a “stop-the-clock” mechanism or to introduce a simplification review clause would extend existing legal and market uncertainty. According to the group, such measures would leave companies unclear about the final provisions of the regulation and risk undermining investments already made to prepare for compliance.

The statement notes that companies, producing countries, and smallholder farmers have been preparing for the regulation’s due diligence obligations, and that ongoing uncertainty could affect their ability to adjust supply chains and operational systems.

Concerns About a One-Year Delay

The group also opposes introducing a one-year delay, stating that it would recreate the uncertainty experienced throughout 2024 and 2025. The coalition maintains that a delay would not guarantee that IT systems or administrative structures would be fully operational by 2026. It argues that relevant actors, including operators and national competent authorities, need to begin implementation promptly to gain practical experience with the regulation’s requirements.

Instead of delaying the regulation, the coalition supports creating a defined grace period of at least six months, extendable to twelve. Under this approach, the EUDR would begin applying on schedule by the end of 2025, and companies would start submitting the information needed to generate due diligence statements.

During the grace period, national authorities would not impose penalties for non-compliance on relevant products. According to the coalition, this would provide time for the European Commission to address issues with its IT system and allow companies and authorities to adapt to the requirements while maintaining incentives to work toward compliance.

Traceability Requirements Viewed as Essential

The coalition emphasizes that traceability throughout the supply chain is a core component of the EUDR and should be preserved. While acknowledging that some stakeholders have called for simplifying the due diligence process, the coalition states that the European Commission’s proposed approach of requiring companies to collect and pass on information through the supply chain would create operational challenges. In particular, the group notes that downstream operators could be required to manage large volumes of due diligence statements for each shipment.

To address this, the coalition proposes an alternative system in which:

• Only operators placing relevant products on the EU market submit due diligence statements.
• All companies maintain a due diligence system subject to checks by competent authorities and act on any substantiated concerns regarding their supply chains.
• All companies keep records of their immediate suppliers and customers, similar to requirements under the EU General Food Law.

The coalition asserts that this approach would maintain the regulation’s core due diligence and traceability objectives while reducing administrative burdens.

Impact on Smallholder Farmers

The statement also notes that the European Commission’s proposed adjustments for micro and small operators placing products directly on the EU market would not affect most smallholder farmers in producing countries. Many of these farmers, particularly in cocoa, coffee, palm oil, rubber and timber sectors, do not export directly to the EU. The coalition states that these producers will continue to require support from the EU, member states and companies.

The position is endorsed by a wide range of organizations, including Barry Callebaut, Mars Wrigley, Nestlé, Danone, Ferrero, Olam Agri, the Rainforest Alliance, Solidaridad, Cémoi, Interholco, Precious Woods, SIPH, Tony’s Chocolonely, and others across the food, forestry, commodity and civil-society sectors.

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