They are urging immediate improvements to ensure compliance and operational efficiency.
The information system (or register) aims to facilitate the submission and processing of due diligence statements for relevant operators, traders, competent authorities, and customs to ensure a smooth transition at the end of 2024, when the EUDR rules enter into application.
But it is not yet on track to meet requirements of properly functioning supply chains, argue the food and feed organizations in a letter to Ursula von der Leyen, EU Commission president.
And many questions remain over the Commission's timeline for system readiness, according to the letter.
Further testing urged
In January, companies participated in pilot testing of the initial EUDR information system and provided extensive feedback highlighting numerous gaps and necessary enhancements.
However, during a deforestation platform meeting on April 24, the stakeholders questioned whether the information system, once revised by the Commission, would meet business needs.
“Requirements that are critical for the functioning of business supply chains have been disregarded, notably the need for bulk commodities to manage large volumes of data and for taking into account already used standard formats in which data is being collected for traceability purposes.”
The organizations are urging the Commission to conduct a second round of testing with the business community to address the considerable list of 'inaccuracies and errors' reported during the pilot testing. They emphasized the need for a dedicated stress test to allow companies to upload substantial amounts of geolocation data and requested the API specifications be made available by May. This would enable businesses to revamp their IT systems for integration, a process that requires several months and precise API details.
Due diligence statements
Additionally, the business groups want the Commission to lift or increase the 25MB file size limit for due diligence statement uploads, as they maintain the current limit is insufficient for bulk commodities and derived products. They also requested the acceptance of multiple data formats beyond GeoJson, arguing that pre-existing traceability work relies on various formats.
Moreover, the organizations highlighted the need to make the EUDR information system available for all users by early November at the latest. The current plan to open the system for widespread use in mid-December fails to account for the reality of supply chains, where most autumn harvests may only arrive in the EU after the regulation's application date, necessitating accompanying due diligence statements, they claim.
EU competitiveness at stake
Failure to address these issues could severely impact the Commission’s reputation, access to key supplies, and the competitiveness of EU supply chain actors, reads the letter.
The organizations reiterated their willingness to provide IT expertise and engage in a structured dialogue to improve the system, emphasizing that a well-functioning information system is critical for the successful application of the EUDR.
