Today, CAOBISCO ( European association of chocolate biscuit and confectionery) sent a letter to President von der Leyen regarding the implementation of the European Deforestation Regulation. The date of application of the EUDR is approaching at full speed, while several key components are still further delayed or lacking clarity. This is particularly concerning as companies rely on legal clarity to further adapt their systems, processes and organisational resources to the EUDR requirements and ensure a high level of preparedness.
Given the risks that companies will bear in case of non-compliance, urgent action is required from the European Commission to provide all the necessary tools and systems, as specified in the Regulation, to minimize the risk of market disruptions, food waste and unnecessary administrative burden on companies.
Specifically, our concerns include the following crucial points:
- Due diligence obligations of operators/traders further down the supply chain
- Due diligence for composite products
- Adequacy of the Information System and access to third countries
- Further clarity on the transition period
- Benchmarking system
- Legality requirement
Our letter is available here
