Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

We are asking to include cotton linters in the European Union Deforestation regulation. Not including them is giving an unfair competitive disadvantage to wood pulp suppliers, both raw materials of cellulose ethers production. At the same time is also creating a regional disadvantage to Europe, since the majority of the cotton linters are coming in products from Asia.

Baerlocher welcomes the clarifications provided by the DA to introduce targeted and limited technical fixes. We noticed two discrepancies in the draft delegated act: 1. HS code 382311 (stearic acid) is not listed in the draft delegated act, while being listed in the original Annex I list. It needs to be included in the Delegated Act, with a proposed "ex as it can be derived from tallow and other vegetable oils. 2.

The proposed delegated act brings some clarifications but it does not address the very basic burdensome nature of the provisions of the basic regulation. Provisions of Article 34(5) should be used to reduce the number of CN codes fo products to which the basic regulation applies.

EPAL welcomes and supports the clarification in Annex I No. 4415 that used and second-hand wooden packaging such as pallets will be excluded from the application of the EUDR. This is the urgently needed consequence of the correct regulation that wooden pallets loaded with goods are not relevant products.

Preferred by Nature feedback on European Draft Delegated Act Ref Ares (2025) 3099313 - 15/04/2025 13th May 2025 #1: A formal definition is required of the terms second-hand products and used products. Preferred by Nature supports the intentions of Recital 4 and subsequent revisions to relevant wood and rubber products, to highlight where used products and second-hand products are excluded from the regulation.

We recognize the importance of the EUDRs objectives and understand its role in combating global deforestation. Legislation like this has the potential to transform practices across various supply chains including our own. However, the inclusion of bovine hides and leather in Annex I could lead to negative consequences.

The Brazilian government has been following closely the initiative for a delegated act of the European Commission proposing adjustments to the so-called Anti-Dekilling Law (EUDR). Brazil appreciates the opportunity to comment on the initiative. 2.

Filed in Portuguese · English published by the European Commission

Dear Members of the European Commission, Please find attached our contribution to the public consultation on the draft Delegated Act concerning the proposed amendment to Annex I of Regulation (EU) 2023/1115 on deforestation-free products. This submission presents our technical position regarding the inclusion of bovine leather within the scope of the EUDR.

Bioenergia ry - the Bioenergy Association of Finland - supports the amendment of Annex I to the Deforestation Regulation to clarify the commodities under Regulation (EU) 2023/1115. While we acknowledge the importance of avoiding deforestation and forest degradation to prevent species and habitat loss, and to mitigate and adapt to climate change, we understand and support the goal of avoiding unnecessary…

Comité Européen des Entreprises Vins (www.ceev.eu), CEEV, welcomes the opportunity to contribute to the public consultation on the Delegated Regulation amending Annex I of the EU Deforestation Regulation. By way of introduction, CEEV represents the European Union wine companies and brings together 25 national organisations from 13 EU Member States, plus Switzerland, United Kingdom and Ukraine, as well as a…

With regard to the EUDR our members can be primarily characterized as companies in the downstream supply chain which produce and trade relevant (composite) products and thus fall within the scope of the EUDR. The green sector industry is currently working intensively to implement and meet the future requirements of the EUDR. The Industrieverband Garten (IVG) e.V.

Meat production and milk production from cattle lead to offal. This includes hides, but also hooves, horns, bones, offal. These by-products are mandatory in livestock farming. The animals are not kept because of the by-products. The products obtained from the marketing of meat and milk are determining the value of the product.

Filed in German · English published by the European Commission

1. FAQ 2.12 directly contradicts the Draft Act Ares(2025)3099313 EU rules to minimise deforestation & forest degradation amendment of Annex I to the Deforestation Regulation We suggest the Draft Act be updated to reflect the language in EUDR FAQ Version 4 April 2025 Products made solely from bamboo are not in scope of the EUDR. Art. 1.. The definition in Art.

The European Tyre and Rubber manufacturers Association supports the technical clarifications brought by the latest FAQ as well as by the Draft Delegated Act. The combination of the two documents, achieves the following objectives: 1. Excludes tyres used for testing from the scope 2. Excludes used and second hand tyres from the scope 3. Excludes waste from the scope 4.

Feedback on the planned amendment of Annex I to Regulation (EU) 2023/1115 (EUDR) The Würth Group welcomes the European Commission’s efforts to make the EUDR more feasible through targeted clarifications and practical adjustments and strongly supports the present draft. 1.

Filed in German · English published by the European Commission

Curtidos Badia SAU, is a tannery that works in the UE Leather is a meat industry byproduct. Scientific studies (Santa Anna School, Pisa University, and Montana State University) demonstrate that there is no link to deforestation. Bringing leather under the EUDR will generate a significant negative economic and social impact (job losses). The industry is not prepared to handle the economic impact.

As the trade association representing the European bioenergy sector, Bioenergy Europe welcomes this opportunity to comment on the amendments to Annex I of EUDR. In particular, we would like to highlight three suggested revisions that are in light with the goal of the European Commission to reduce administrative burden to operators and competent authorities, while maintaining the focus of EUDR in the fight against…

Retreading Nortiver is an SME (Small Media Enterprise) based in Portugal, and is one of the largest manufacturers in the country, with a wide range of retreaded tyres from car, truck and OTR. The retreading activity has made a very significant contribution to the circular economy by reusing carcasses (used tyre) that have already moved and had a life; this saves thousands of tonnes of CO2 and original fossile raw…

Filed in Portuguese · English published by the European Commission

Febelgra is the professional federation representing Belgian printing and graphic companies. We welcome the draft delegated regulation that provides clarity regarding the status of certain printed products, particularly the exclusion of packaging materials and correspondence items, as well as the exclusion of accessory printed materials accompanying another product.

The Federation of the European Sporting Goods Industry (FESI) welcomes the opportunity to provide feedback on the European Commissions proposed delegated regulation on the EU Deforestation Regulation (EUDR). FESI fully supports the goal of minimising the EUs contribution to global deforestation.

The Maison des Vins et Spiritueux, an entity bringing together the Fédération des Exportateurs de Vins et Spiritueux de France (FEVS), the Fédération Française des Spiritueux (FFS), the Fédération Française des Vins dApéritif (FFVA) and the Union des Maisons des Marques de Vin (UMVIN), wishes to make the following contribution on the draft delegated act, which aims to clarify the list of products covered by European…

Filed in French · English published by the European Commission

The French Publishers Association fully supports the goal of ensuring legal clarity for operators, traders and surveillance authorities on the categories of products falling within the scope of the EUDR. As representatives of book publishers, we particularly welcome further clarifications regarding the exclusion from the scope of packing materials and packing containers and of accessory materials (namely marketing…

In principle, clarifications are welcome, but ex... has now been added to most HS codes. In conjunction with FAQs point 2.2. it is understandable what is meant by this, but ex... is not a terminus technicus from a legal point of view. The exceptions are actually largely only set out in the non-binding FAQs and guidelines, but not in the text of the regulation itself. In our opinion, ex...

We Gobba Leather produce finished hides and crust hides with skins of animals from Brazilian origin, which are by-products from meat product chain. We consider the leather hides as a sustainable, longstanding with unique characteristics.In our opinion the cattle breeding is not being addressed to by -products demand, but for the meat production.

Dear Members of the Commission. As a company, we are defenders and practitioners of sustainable actions, positioning ourselves against illegal deforestation. As a tanning company, we understand that bovine hides and skins should be removed from Annex I of the EUDR, since studies carried out by renowned and impartial organizations prove that hides and skins are not agents that cause deforestation.

We welcome the opportunity to provide feedback on the proposed revision of Annex I of Regulation (EU) 2023/1115 on Deforestation-free Products (EUDR). As a responsible manufacturer, we support the objectives of the EUDR and its mission to reduce deforestation and forest degradation by promoting more sustainable supply chains.

The European Furniture Industries Confederation fully supports the EU Deforestation Regulations objective to combat global deforestation. Nevertheless, it is crucial to ensure that it is implemented under the right conditions, to be both effective and feasible.

We are mechanical engineers who do not sell directly any EU of the relevant product. We are concerned with the EUDR through spare parts, marketing materials and other by-products. We want to exclude by-products such as marketing materials, giveways, etc. at fairs. In our view, there is also a need for clarification on how to deal with distance sales (klares eCommerce Busieness).

Filed in German · English published by the European Commission

We welcome the EU Commission's intention to simplify and reduce the administrative burden in relation to the implementation of the EUDR and to respond to outstanding open issues and feedback from affected stakeholders.

Eastman appreciates the clarifications provided by the updated draft Delegated Act, which aims to introduce targeted and limited technical adjustments. However, we believe that a comprehensive review of Annex I is essential to prevent serious disruptions in European supply chains, which could inadvertently affect the availability of essential goods in the European market.

The U.S. Industrial Pellet Association (USIPA) represents the transatlantic supply chain for industrial wood pellet exports from the U.S. Southeast. Our members support EU energy security and climate goals by supplying renewable biomass for power, heat, and industry, and will play an essential role in carbon removals and sustainable fuels.

Protection of human rights and sustainable sourcing of raw materials are a high priority for the chemical-pharmaceutical industry in Germany. The EU Regulation 2023/1115 (EU Deforestation Regulation, EUDR) for deforestation-free supply chains could be one possible instrument supporting implementation of high environmental and social standards along the value chain of soy, oil palms, cattle, coffee, cocoa, rubber…

We welcome the proposed delegated act which responds to some of our outstanding queries and provides additional clarity, simplification and legal certainty in support of the preparation for the date of application of the EUDR for the retail and wholesale sector.

The European Publishers Council (EPC) is a high-level group of Chairmen and CEOs of Europes leading media groups representing companies which are active in news media, television, radio, digital market places, journals, eLearning, databases and books.

As the trade association representing the European bioenergy sector, Bioenergy Europe welcomes this opportunity to comment on the amendments to Annex I of EUDR. In particular, we would like to highlight three suggested revisions that are in light with the goal of the European Commission to reduce administrative burden to operators and competent authorities, while maintaining the focus of EUDR in the fight against…

On behalf of the Coalition on Sustainable Timber, we welcome the opportunity to provide feedback on the Annex I the Deforestation Regulation. We fully support the EUs commitment to combating global deforestation and forest degradation, and we offer the following recommendations to enhance the effectiveness, fairness, and inclusiveness of the Regulation.

Global Witness welcomes the draft Delegated Act amending Annex I of the EU Deforestation-Free Products Regulation (EUDR). The proposed approach to harmonise the list of certain products on the basis that they are not made from the relevant commodities of the EUDR, meanwhile maintaining the full list as adopted by the co-legislators, is an important step forward to ensure an effective implementation and enforcement…

FoodDrinkEurope appreciates the opportunity to contribute to the public consultation on the Delegated Regulation amending Annex I of the EU Deforestation Regulation. Please find attached FoodDrinkEurope's feedback, notably the request for clarification on certain specific provisions and the consideration of several key recommendations.

The Italian Publishers Association (AIE) appreciates the opportunity to contribute to the present consultation and fully supports the goal of ensuring legal clarity for operators, traders and surveillance authorities on the categories of products falling within the scope of the EUDR.

Confapi welcomes the opportunity to contribute to the public consultation on the Commissions draft Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EUDR), and appreciates the efforts made to improve legal clarity and reduce compliance burdens, particularly for SMEs.

As the European Commission reviews its proposed amendments to Annex I of the EU Deforestation Regulation (EUDR), it must ensure that its requirements provide regulatory certainty and do not create further obstacles to implementation. Specifically, it must ensure consistency, greater clarity and fewer compliance burdens in key provisions.

Imperial Brands PLC is a FTSE 100 company headquartered in the UK with a significant presence in the EU and is the parent company of a dynamic international business specialising in tobacco and non-tobacco products. We welcome the opportunity to contribute to the ongoing public consultation concerning the Draft Delegated Act amending Annex I of the EU Deforestation Regulation (EUDR).

We acknowledge and support the Commission's efforts to promote waste recovery and the transition to a circular economy. However, we note that the Delegated Act would extend the existing exception for "waste" products to second-hand and used products.

FEC, the European Federation of Manufacturers of Cookware and Cutlery, welcomes the opportunity to comment on the proposed revision of Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation - EUDR). Firstly, we would like to highlight the inconsistency on bamboo, rattan, and other materials of woody nature in the two documents, particularly in recital (3) and paragraph (3) of the Annex.

CAOBISCO and its member companies are fully committed to the objectives of the EU Deforestation Regulation (EUDR) and to its successful implementation. To this purpose, we greatly appreciate the opportunity to participate in the ongoing European Commissions public consultation on the draft delegated act amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant…

We want cattle hides, skins and leather to be excluded from Annex I of EUDR (all products of HS chapter 41). Here our key arguments for Exclusion: 1.Hides Are By-Products, Not Deforestation Drivers: -Cattle are primarily raised for meat and dairy, not for hides. -Hides do not incentivize cattle farming, and including them under EUDR does not significantly reduce deforestation.

MOBILIANS, representing the automotive aftermarket services sector in France, welcomes this proposal and the accompanying documents, and would like to offer further recommendations on the delegated act and the Regulation. Please find our position paper with our proposals attached.

Börsenverein des Deutschen Buchhandels e.V. (German publishers and booksellers association) fully supports the goal of ensuring legal clarity for operators, traders and surveillance authorities on the categories of products falling within the scope of the EUDR.

Mobivia is an independent family group, a European leader in servicing, maintenance and automotive equipment that accompanies over 30 million customers thanks to a wide portfolio of brands such as Norauto, Midas, Carter Cash or ATU. Present in 16 countries with 2000 centres and 23 000 collaborators, it combines economic performance, innovation and commitment to the green transition.

Filed in French · English published by the European Commission

spiritsEUROPE represents the interests of European spirits producers at EU level. Our membership is made of 30 national associations who represent both large and small spirits producers and 11 leading international spirits companies.

The concern of the Malaysian rubber industry is on products that has both natural rubber and synthetic rubber; this is specifically for a product that has more than 50% of synthetic rubber component (which is not affected by EUDR) compared to natural rubber: 1.

We welcome the opportunity to provide input on the draft Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 on deforestation-free supply chains (EUDR). Our members remain committed to supporting responsible sourcing practices and sustainability objectives.

The Federation of European Publishers (FEP) represents 31 national associations of publishers of books, learned journals and educational materials form 30 countries across Europe - mainly in the EU and EEA. FEP fully supports the goal of ensuring legal clarity for operators, traders and surveillance authorities on the categories of products falling within the scope of the EUDR.

We believe that hides and skins have been improperly included in Annex I and should not be subject to the EUDR. We would therefore ask you to remove them from the list. Leather is produced from raw hides, which are a by-product of the meat and dairy industry and thus have no direct impact on deforestation.

Filed in Portuguese · English published by the European Commission

The draft of delegated regulation wants to make clear that waste as defined in Article 3, point (1) of Directive 2008/98/EC of the European Parliament and of the Council , do not fall within the scope of Regulation (EU) 2023/1115.

The EU Deforestation Regulation (EUDR) aims to reduce deforestation driven by the consumption of agricultural and forestry products generated on land deforested after 31 December 2020. According to our knowledge of the sector and the market, the inclusion of leather in this Regulation is unnecessary for the following reasons: 1.

Filed in Spanish · English published by the European Commission

SNIAA (French Flavour Association) represents flavour houses in France, small, medium size and large companies producing food flavourings. SNIAA is member of the European Flavour Association (EFFA). Flavourings are essential food ingredients that contribute to safe, sustainable and enjoyable food choices for consumers.

Among the products covered by the EUDR are raw hides and skins (4101) and those derived after the various stages of the tanning process (4104, 4107). This is a serious error because raw hides and skins are an animal by-product (ABP), which is created as a waste from the slaughter of the animal, which has as its sole purpose the production of meat for food purposes.

Filed in Italian · English published by the European Commission

3M welcomes the opportunity to contribute to the public consultation on the proposed amendment to Annex I of the Regulation (EU) 2023/1115. We support the objectives of the EU Deforestation Regulation (EUDR) and EU Commissions efforts to clarify and simplify the implementation of it.

The German automotive industry welcomes the European Commission's proposal on amending Annex I of the EUDR. However, with regard to prototype components and test parts, the focus should be on the intention to use prototype parts exclusively for testing purposes instead of having to prove that these components are entirely used up or destroyed.

Statement by Deutsche Umwelthilfe on the Amendment of Regulation (EU) 2023/1115 with regard to the List of Relevant Commodities and Products Deutsche Umwelthilfe (DUH) supports a broad product scope that includes all major commodities associated with deforestation. A narrowing of the current scope would reduce the Regulations overall effectiveness and should be avoided. 1.

We welcome the clarifications provided by the DA to introduce targeted and limited technical fixes. At the same time, following the targeted stakeholder consultation by IEEP, an extensive review of Annex I is necessary to avoid serious disruptions in the supply chains, with potential unintended negative effects on the supply of essential goods for the European market.

The EUDR’s clarity on the leather sales market in Europe will be devastating as only Europe will be subject to this heavy standard in its sales worldwide, while other non-EU countries will be able to market among themselves without being subject to all these standards.

Filed in Italian · English published by the European Commission

In the view of the German Farmers’ Association, the changes proposed by the Commission are a first step in the right direction, but remain completely insufficient and do not reflect the actual situation in Germany and many European Member States.

Filed in German · English published by the European Commission

Brazil is one of the largest exporters of commodities to the European Union (EU). According to information from the CICB (Brazilian Center of Tannery Industries), in 2023, the EU had a 21.2% share in total Brazilian leather exports, generating a value of approximately US$237 mil.

Dear Members of the Commission Expert Group / Multi-Stakeholder Platform), On behalf of Ekornes AS, an international manufacturer of furniture products with operations across the EEA, EU and global supply chains in raw materials such as wood, and leather, we would like to respectfully submit our observations and seek formal clarification regarding the EEA relevance and implementation timeline of Regulation (EU)…

The Rainforest Foundation Norway (RFN) supports the intention of introducing limited and targeted technical fixes to Annex 1 of the EUDR. We have no objections to any of the amendments proposed. However, we have noted the large number of submissions calling for bovine hides and leather (HS codes 4101-4104-4107) to be excluded from the Annex on the grounds that they are allegedly only by-products of cattle…

The drogerie markt (dm) group welcomes the European Commission's decision to clarify the context of Annex 1, which will facilitate a better understanding and implementation of the regulation for operators and traders. Overall, we are pleased with the content of the amendment.

APPLiA members highly appreciate the publication of the updated guidance, the Frequently Asked Questions and the draft Delegated Regulation that amends Annex I of the Regulation (EU) 2023/1115. Altogether, these documents provide a very much needed clarity for companies to understand which products fall within or outside the scope of the Regulation.

We welcome the opportunity to submit our comments on the draft Commission Delegated Regulation Act amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products. 1) We would like to point out a contradiction between point 3 in the delegated regulation and the formal explanation accompanying it.

Danish Industries would like to take this opportunity to express our support for the simplification efforts the EU Commission is undertaking to guide companies in scoping and implementing the EUDR in a proportional matter.

I am very happy to have the opportunity to share feedback on the application of the EUDR regulation. I would like to raise some remaining questions for which we haven't found a clear answer in the latest documents provided by the EU. I also would like to acknowledge that the FAQ (4th Iteration), the Guidance document, and the compliance guide are very useful and have resolved a number of existing uncertainties.

Argument concerning the amendment of Annex I to Regulation (EU) 2023/1115 concerning the exclusion of bamboo, rattan and other woody materials. In relation to the procedure for amending Annex I to Regulation (EU) 2023/1115 on rules to minimise deforestation and forest degradation, we request that the scope of the exclusion provided for other materials of a woody nature be explicitly clarified.

Filed in Spanish · English published by the European Commission

The European Flavour Association (EFFA) represents the flavour industry across Europe, bringing together National Flavour Associationswhose members are primarily SMEsand flavour companies active at European level. Established in 1961, EFFA provides a platform for coordination, expertise and engagement. EFFA is member of the International Organization of the Flavor Industry (IOFI).

FRENCH TANNERS FEDERATION fully supports the main objective of the EUDR regulation, which is to tackle deforestation, nevertheless we challenge the scope of some products which are included in the annex 1. Scientific evidence proving the link between deforestation and production of bovine hides and skins (HS 41) was missing in the original impact assessment that was lead during the preparatory phase, before the…

The BMW Group is aware that forests provide important resources and ecosystem services for both companies and society. In recognition of this, the BMW Group is committed to support minimizing deforestation and forest degradation. Therefore, we would first like to emphasize that we fully support the goals of the EUDR.

We call for the exclusion of bovine hides and skins (customs codes 4101, 4104, 4107) from Annex I to the EUDR as this is a difference in the food production of meat that is not directly responsible for deforestation. This means that tanning confectionery has no influence on the rearing and slaughter of livestock.

Filed in Italian · English published by the European Commission

KRAIBURG AUSTRIA, a leading manufacturer of compounds and materials for the retreading industry, welcomes the European Commissions initiative to clarify the application of the EU Deforestation Regulation (EUDR) to used and retreaded tyres.

CTC is the industrial technical center (CTI) and the Professional Committee for Economic Development (CPDE) for the French Leather, Footwear, Leather Goods, Gloves industries. With the support of the professional associations, CTC oversees a general interest mission for the benefit of nearly 900 french industrialists in the raw hides, tanning, footwear, leather goods and glove industries supporting companies in…

The German Pharmaceutical Industry Association (BPI) represents the common economic interests of its member companies, particularly in the areas of healthcare and location policy, security of supply and pharmaceutical legislation at state and federal level as well as in Europe.

The Austrian Chamber of Agriculture supports the aim of this regulation which is stopping global deforestation but underlines that its current requirements are neither fit for purpose nor proportionate as they exempt EU farmers and foresters from any market interaction if they do not prove that their area is deforestation free (although the pastures and soy fields have been arable land since centuries and the forest…

European farmers and agri-cooperatives welcome the initiative from the European Commission to open the Annex I of the EU Deforestation Regulation and to consult stakeholders on this proposal. However, no simplification for farmers, forest owners and their cooperatives is proposed.

As representatives of the European tannery, we would like to draw attention to problems related to the implementation of Regulation (EU) 2023/1115 on products associated with deforestation (EUDR). We believe that appropriate legal measures are needed for the protection of the environment, especially in regions at risk of deforestation.

Filed in Polish · English published by the European Commission

Earthsight submits the comments below to the European Commissions public consultation on the amendment of Annex I to the Deforestation Regulation (EUDR). This amending act is intended to provide technical fixes and clarifications and should not be used to relitigate the scope of commodities covered by the Regulation.

We request that bovine hides, skins and leather (all HS Chapter 41 products) be excluded from Annex I of the EUDR. As a by-product of the meat sector, leather does not drive deforestation. This fundamental distinction was not fully considered in the EUDR's impact assessment.

Objection regarding the Amendment of Annex I of Regulation (EU) 2023/1115 in relation to the exclusion of bamboo, rattan, and other woody materials In the context of the procedure to amend Annex I of Regulation (EU) 2023/1115, which establishes rules to minimize deforestation and forest degradation, we request that the scope of the exclusion for "other woody materials" be expressly clarified.

Our paper carton case is under the scope of EUDR. We purchase it from Japan suppliers, and we heard that in order to maintain the quality and price of the pulp and chips used in each paper carton case, the source of the wood for the paper are not always the same but are instead purchased from multiple suppliers.

Aligned with our previous position and calls for a swift, unchanged adoption of the EUDR, Fedima believes that it is premature to extend or modify the scope of the regulation at this stage. The one-year postponement of the EUDR was intended to give operators time to adapt to the existing requirements; not to accommodate further changes during the transition period.

We are grateful for the opportunity to submit comments on the proposed amendments to Annex I of the EU Deforestation Regulation (EUDR), and we sincerely thank the Commission for the clarifications provided concerning the Regulations scope. Please find below our observations, and we respectfully welcome any corrections or further clarifications should any part of our understanding be inaccurate.

The proposed exclusion of second-hand or used products from the EUDR scope must be clarified and defined to avoid EUDR circumvention. While it is reasonable to exempt products already placed on the market, the delegated act lacks clear definitions and proof requirements for identifying such products.

Scientific studies by Montana State University and Sankt Anna School of the University of Pisa show that hides, skins and leather of cattle are not a cause of deforestation. The inclusion of hides and leather in the scope of the EUDR would have a devastating economic and social impact on the leather sector and would lead to massive job losses in the EU leather value chain.

Filed in German · English published by the European Commission

The European Express Association (EEA) is pleased to provide its feedback to the consultation regarding the "EU rules to minimise deforestation & forest degradation amendment of Annex I to the Deforestation Regulation" in its attached document, which includes both the reply on the public consultation and its position paper on the EUDR.

The Federation Française des Cuirs et Peaux is an organization connecting the breeding sector, slaughterhouses, and tanneries to ensure responsible, high-quality sourcing and processing of hides and skins. We fully support the main objective of the EUDR regulation, which is to struggle deforestation, nevertheless we challenge the scope of some products which are included in the annex 1.

In relation to Annex I to the Deforestation Regulation, I would like to make the following comments: bamboo ratan; more than clarification of bamboo and rattan products has created more confusion. It should be fully identified whether they enter or fall outside the EUDR Regulation.

Filed in Spanish · English published by the European Commission

The Stuttgart Chamber of Commerce and Industry is one of the largest chambers of Germany. It represents the overall interests of its approximately 175.000 member companies vis-à-vis politics and administration, and promotes the industrial economy, taking into account the economic interests of individual industries and businesses in a balanced manner.

Filed in German · English published by the European Commission

Good day, we have our vision as a concert of the EUDR regulation. Scientific evidence shows that the skin of bovine origin, as a mere derivative of the meat industry and with a low economic weight, has no bearing on husbandry practices and decisions on the slaughter of animals. It cannot therefore be held responsible for deforestation processes.

Filed in Italian · English published by the European Commission

Raw bovine skin is an animal by-product (ABP), the availability of which is an ancillary consequence of the slaughter of livestock, reared only for meat. Bovine hides and skins are not responsible for deforestation; this is, to all intents and purposes, a gap in the food industry, whose sales value by the slaughterhouse is so low that the tanning industry has no influence on the rearing and slaughter of livestock.

Filed in Italian · English published by the European Commission

1. Adding ex prefix to HS codes of products: The addition of the ex prefix to HS codes of relevant products that can originate from other commodities which are out of the EUDR scope is needed to denote that such products (made from out-of-scope commodities) are indeed out of scope for compliance and enforcement with EUDR. We therefore welcome the Commissions proposal to correct Annex I in this sense.

We really want to understand why the raw bovine skin was included in Annex I to the EUDR. When the EU focuses on the bio-economy and encourages eco-design, we sincerely feel a counter-sense to include in the EUDR the slaughter waste from cattle that has always been recycled and notable through tanning.

Filed in Italian · English published by the European Commission

The inclusion of hides, skins and leather in the EUDR would have a very negative impact on the economy and society, as it is feared that the competitiveness of the leather sector would be severely reduced and the sectored would be destroyed. This would lead to massive job losses in the EU leather value chain.

The proposed approach to maintain the initial list of relevant commodities and products in the EUDR scope and to exclude certain products only on the basis that they are not made of relevant commodities will support the implementation of the legislation.

The German food and beverage industry supports the goals of the European Union to reduce deforestation in international supply chains. However, the effective functioning of supply chains depends on a pragmatic, clear and harmonised approach that can be implemented by all companies in the EU and abroad and especially by companies of all sizes.

Dear all, AidEnvironment underscores the critical importance of retaining leather as part of Annex 1 of the European Union Deforestation Regulation (EUDR) to ensure the protection of forests in cattle-producing countries.

Samsung Electronics (SE) welcomes the review of EUDR Annex I by the European Commission (EC) pursuant to Article 34. Securing the 1-year application delay (i.e., end-2025) has been a step in the right direction allowing companies to adapt their business model upon the newly established requirements, and the EC to issue guidance, secondary law, and other supporting measures for effective implementation.

Danske Erhverv would like to thank the European Commission for the possibility of submitting a consultation response to the Commission’s draft delegated act amending Annex I to the Regulation on combating global deforestation and forest degradation. Dansk Erhverv supports the political ambition to combat global deforestation.

Filed in Danish · English published by the European Commission

Good morning. We are CONCERIA THE VENETA SPA. We are writing on the EUDR anti-deforestation regulation. Our question is: WHAT DOES THE SKIN DO WITH DEFORESTATION? We cannot understand it with the broadest possible will. Tanning companies, like ours, are only processors of a product (skin) which appears to be a waste from the meat industry, which would otherwise be landfilled or incinerated.

Filed in Italian · English published by the European Commission

APAG & CESIO (Cefic sector groups representing the European oleochemicals and surfactants industries) welcome the clarifications provided by the Delegated Act to introduce targeted and limited technical fixes. We noticed two discrepancies in the draft delegated act: 1. HS code 382311 (stearic acid, industrial) is not listed in the draft delegated act, while being listed in the original Annex I list.

We noticed three discrepancies in the draft delegated act: HS code 382311 (stearic acid) is not listed in the draft delegated act, while being listed in the original Annex I list. It should be included in the Delegated Act, with a proposed "ex as it can be derived from tallow and other vegetable oils.

We, the Korea Tire Manufacturers Association (KOTMA), represent the leading tire manufacturers in Korea, including Hankook Tire & Technology Co., Ltd., Kumho Tire Co., Inc., and Nexen Tire Corp. As key stakeholders in the global tire industry, our members are committed to ensuring full compliance with the European Union Deforestation Regulation (EUDR) and supporting the EUs sustainability objectives.

GME, the Gelatine Manufacturers of Europe (GME), is the leading association of Europe's foremost gelatine manufacturers. GME's mission is to serve the European gelatine industry, to support the products gelatine and collagen peptides and also to inform and communicate with customers, authorities and the media.

Comments from the Korean Paper Industry on the Implementation of the EUDR As a representative body of the Korean paper industry, we respectfully submit the following comments regarding the EU Deforestation Regulation (EUDR): 1. Trade Status As of 2024, only a limited number of Korean companies export paper products to the EU, primarily printing and thermal paper.

Please find below the key messages from the Japan Business Council in Europe (JBCE) . (1) Simplified implementation of the EUDR is essential to ensure feasibility and effectiveness across industries. (2) Greater flexibility should be introduced to allow the submission of single due diligence statements covering multiple shipments/batches from a variety of sources.

The Couro should be excluded from Annex I of EUDR, including all products of Chapter 41 of the Combined Nomenclature, for the following reasons: — The Couro is not a driver of deforestation, since it is an animal by-product of cattle farming. Cattle farmers, rearing cattle to obtain meat and leather is a by-product of this activity.

Filed in Portuguese · English published by the European Commission

The EU Deforestation Regulation is an important measure in the effort to reduce global forest loss. The world is currently losing 10 football fields of tropical forests every minute. Given that the EUs imports of commodities account for 13-16% of global deforestation, despite representing only 7% of the worlds population, its environmental footprint and consumer influence are disproportionately large.

Established in London in 1897, the International Union of Leather Technologists and Chemists Societies is the largest global scientific organization focused on leather. It comprises 17 Member Societies, 6 Associate Members, and 2 Supporting Members, representing approximately 3000 individuals.

As created FAQs and consequently Q&A point 2.8.1 is correct, that does not concern used tyres and retread tyre casings. However Annex 1 does not clearly state this. Annex 1 to be clearly modified with text used Tyres and tyre casings used for reyteads are exempt. Tyre retreading is recycling, and used tyres and tyre casings used for retreading have already fulfilled requirement in their first service life

Response of SAVONNERIE de lATLANTIQUE to the Public Consultation on the European Regulation (EUDR) on Deforestation-Free Supply Chains Based on the Targeted Stakeholder Consultation Questionnaire on the Scope of Annex I, submitted to the IEEP/European Commission on 13/02/2025

The European Automobile Manufacturers' Association (ACEA) in general welcomes the EU Commission's efforts to provide further guidance and clarity on the implementation of the EU Deforestation Regulation (EUDR). However, key issues remain, adding additional/unnecessary burdens and leading to legal uncertainties for our industry.

O Centro das Indústrias de Curtumes do Brasil (CICB) é a entidade que representa os curtumes brasileiros. Atuamos há quase 70 anos na defesa e no fortalecimento do setor de couros do país no âmbito doméstico e internacional, promovendo práticas sustentáveis, inovação tecnológica e comércio responsável.

The European Coffee Federation (ECF) welcomes the opportunity to contribute to the public consultation on the Delegated Regulation amending Annex I of the EU Deforestation Regulation. Please find attached the ECF's feedback, with a focus on the non-inclusion of soluble coffee (HS code 2101 11) in the annex, as well as on the aspects related to the exclusion of samples from the EUDR scope.

As an association of the German leather industry, we support the EU’s efforts to stop deforestation of rainforests. However, we are convinced that this law is too complicated, too bureaucratic. This is because larger and large companies have to start six months ahead of the smallest and smallest ones.

Filed in German · English published by the European Commission

In the context of the ongoing consultation on the adaptation of Annex I to Regulation (EU) 2023/1115, we would like to highlight three key points of particular practical relevance from the point of view of the confectionery sector.

Filed in German · English published by the European Commission

Position of the German Construction Industry Federation on the EU Deforestation Regulation (EUDR) The German Construction Industry Federation (HDB) welcomes the opportunity to express its general position on the EU Deforestation Regulation (EUDR) beyond the scope of the current consultation on the delegated act.

As a company specialized in providing state-of-the-art software for global supply chain traceability, Sourcemap appreciates the opportunity to provide feedback on the draft Delegated Act revising Annex I of the EU Deforestation Regulation (EUDR).

The Confederation of National Associations of Tanners and Dressers of the European Community (COTANCE) represents the European tanning sector (+/- 1500 tanneries and 30,000 workers). It gathers 10 national member organizations (DK, FR, DE, HU, IT, NL, PT, ES, SE, UK) accounting for some 90% of Europes leather production. With 25% of the sectors worldwide turnover, it is an important player in the leather market.

Particleboard and fiberboard Particleboard and fiberboard are made exclusively of residual wood materials, such as sawmill residues and low-grade wood (including thinning timber) from plantations or afforestation, which cannot be used for other purposes, such as building materials or furniture manufacturing. Nevertheless, the EUDR will apply to products produced using wood.

The issue of the environmental impact of the hides and skins industry is often debated, but it is crucial to analyse the facts objectively. Raw bovine skin is an animal by-product (ABP) derived mainly from the meat industry. It is essential to understand that skin is not the primary cause of livestock farming, but an ancillary result.

Filed in Italian · English published by the European Commission

Stopping deforestation is an important goal. The path to achieve this goal should serve the goal itself and be as unbureaucratic as possible. Unfortunately, the Deforestation Regulation (EUDR) in its current form does not fulfill this requirement. The resources that companies currently have to spend on assessing their impact, developing and establishing processes are considerable.

Thank you for the opportunity to provide input. Based on our experience with implementing the EUDR compliance program, we recommend introducing an additional interpretative guidance or modifications to the Delegated Regulation that would resolve the issue of distinguishing goods made from natural rubber: The CN classification of rubber products does not allow for distinguishing between products made of natural…

As a non-EU country deeply integrated into the global leather value chain, Turkiye respectfully urges the European Commission to exclude cattle hides, skins, and leather (HS Chapter 41) from the scope of the European Union Deforestation Regulation (EUDR).

Ladies and gentlemen, regarding the proposed amendments to Annex I to the EUDR, I would like to draw your attention to two key aspects. 1. Disproportionate burden on small and medium-sized enterprises The implementation of the EUDR poses significant challenges, in particular in terms of traceability, documentation and risk assessment.

Filed in German · English published by the European Commission

Representing over 100.000 companies, the European printing industry is actively preparing for the compliance of its companies, who are generally considered as downstream operators under the European Deforestation Regulation (EUDR). Printing companies manufacture printed products classified under HS 49.

We are an affected company which produces 100 % in Germany and processes exclusively ‘European cream products’ (e.g. the name of hides of cattle reared and slaughtered in the EU). These by-products from meat production (listed in draft ex4101, ex4104 and ex4107) are to be deleted from Annex 1 to Regulation (EU) 2023/1115 EUDR.

Filed in German · English published by the European Commission

We, Wollsdorf Leather are a Fully integrated Tannery and are producing Finished Leather and Leather half fabricates for further processing starting from raw bovine hides. Our raw materials, the raw bovine hides, fresh or salted as well as WW (wet white) hides as semi-finished raw material are as per current formulation of EUDR Regulation and its Annex I impacted, and required to conduct due diligence and submit a…

Cattle are raised primarily for meat. Cattle are not killed for making leather. Leather is a waste product of cattle industry. As long as meat eaters are around the globe, hides fall out as a waste. Tanneries around the world make use of this waste product to create a useful product called Leather. The leather has a long durability and can be composted when manufactured responsibly thus contributing to circularity.

We are an affected company which produces 100 % in Germany and processes exclusively ‘European cream products’ (e.g. the name of hides of cattle reared and slaughtered in the EU). These by-products from meat production (listed in draft ex4101, ex4104 and ex4107) are to be deleted from Annex 1 to Regulation (EU) 2023/1115 EUDR.

Filed in German · English published by the European Commission

Pernod Ricard are the worlds second-largest wine and spirits group with over 200 spirits and wines brands distributed in 160 countries. Pernod Ricard puts its expertise at the service of authentic moments of sharing, while acting ethically and responsibly to have a positive impact on society and on the planet.

There should be no obligation to state DDS number in export or import declaration. A code for "fulfilled obligations" ought to be enough through a Y-code. And upon any control by customs authority we must be able present correct data. To supply DDS to brokers is a complicated process since one HS-code might have multiple DDS numbers for both export and for re-import.

On behalf of PWPW S.A., I hereby request: (1) in Annex I, in the column ‘Products concerned’, after the entry ‘Product under consideration’, the unconditional exclusion from the scope of the Regulation of products which are tested, analysed or tested, i.e.

Filed in Polish · English published by the European Commission

The European Cocoa Association (ECA) would like to thank the European Commission for the opportunity to contribute to this call for feedback. Please find attached the ECA's feedback regarding the proposed amendments to Annex I of the EU Deforestation Regulation.

Leather UK is committed to protecting the unique identity of leather as a sustainable and beautiful product and working together as one united sector to promote the UK leather brand at home and abroad. The UK leather industry is deeply concerned by the imminent implementation of the EU Regulation 2023/1115 on deforestation-free products (EUDR) and the implications for trade in raw materials and bovine leather with…

The International Council of Tanners (ICT) is the global organisation for the leather producing industry. ICT is deeply concerned about the implications of the EU Deforestation Regulations (EU-DR) for the global leather supply chain. Leather manufacturers have no influence on the first stages of the supply chain, where deforestation occurs, and are not involved in the sourcing and tracing of livestock.

Annex I to the Regulation includes certain by-products and their derivatives, such as raw bovine skin (ex 4101, ABP by-product within the meaning of Regulation (EU) No 1069/2009) and semi-processed (ex 4104) and finished bovine skin (ex 4107).

Filed in Italian · English published by the European Commission

Espirituosos de España is the Spanish Federation of Spirits, an entity that groups 100% of the producer and distributor sector of spirits and derived products in Spain. i. Packaging materials We welcome the revised wording clarifying that certain packaging materials used to support, protect or carry another product placed on the market, and presented with that product, are excluded from scope.

Zschimmer & Schwarz Italiana welcomes the clarifications provided by the DA to introduce targeted and limited technical fixes. We noticed two discrepancies in the draft delegated act: 1. HS code 382311 (stearic acid) is not listed in the draft delegated act, while being listed in the original Annex I list.

Bovine hides and skins are a by-product of the meat market. It is therefore not appropriate to make them subject to highly binding rules, given the nature of the circular economy, since it is in fact a reuse of a food market waste.

Filed in Italian · English published by the European Commission

Hides and skins are exclusively by-products of the food industry. No cattle is slaughtered primarily for its skin. The production of hides and skins is closely linked to meat and milk production. Regulating them as if they were drivers of deforestation is an objectively unjustified shift of responsibility.

As Lavazza Group, we would like to submit the following feedback on the Delegated Act: - Please confirm that marketing materials (or any similar relevant product) are to be considered out of scope also when, after their first placing on the EU market (import or manufactured in EU), they are made available on the EU market again after the import, on the basis of an agreement which does not entail transfer of…

OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of EU organic processing and trade companies, as defined in Regulation (EU) 2018/848 on organic production and labelling of organic products. OPTA Europes members account for a large share of total trade of certified organic ingredients & products.

A number of concerns regarding EUDR implementation have been raised by various stakeholders including forest sectors. Here, we would like to comment on substantial issues in which our sector may face a destructive impact on our sustainable value chain. The main part of raw materials for paper making is recycled paper.

The German Rubber Manufacturers Association welcomes the approach to amend annex I of the regulation (EU) 2023/1115 to clarify existing ambiguities in the regulation in a legally binding manner and to introduce technical fixes to address its unintended negative effects on the sustainable use of resources. However, adjustments will have to be made to the draft amendment of annex I to achieve this.

We respectfully submit the following observations on behalf of British American Tobacco, a manufacturer and distributor of tobacco and non-tobacco products within the European Union, in response to the ongoing public consultation concerning the implementation and interpretation of the EU Deforestation Regulation (Regulation (EU) 2023/1115) ("EUDR"). 1.

We welcome the opportunity to submit our comments on the draft Commission Delegated Act amending Annex I to the EU Deforestation Regulation (EUDR), currently open for public consultation until 13 May 2025. We note and support the proposed amendment of the column ‘Relevant products’ of Annex I, in particular the addition of clarifications following the entry ‘ex 4012 retreaded or used rubber pneumatic tyres; solid or…

Filed in French · English published by the European Commission

In our opinion, requiring each bovine hide to be recorded multiple times through due diligence statements makes no sense. The supply chain for collagen and gelatine is complex, and the same piece of material can be traded through multiple business prior to its final destination. For example one step could be: farm slaughterhouse broker tannery broker collection centre.

The South Tyrol Farmers’ Association represents over 20.000 farmers and forest owners. It welcomes the simplifications included in the proposal through corresponding amendments to Annex I to the EUDR and in principle simplifications to the Regulation in all respects, and calls for further facilitation, in particular for raw materials with secure intra-European provenance, such as the introduction of risk level 0 for…

Filed in German · English published by the European Commission

As of the supply chain, downstream & traceability scope of concern, the initial Annex 1 covered the broad commodities e.g. palm , soya, coffee, cattle, etc. Palm Oleochemicals was not part of the original Annex 1 but was added at a later stage. The major feedstock for palm oleochemicals come from palm stearine (18% of the palm fruit) and palm kernel oil (10% of the palm fruit).

JMC would like to ask the European Commission to take into account the following proposals in the further regulatory simplification activities: 1. Exemption of packaging imported into the EU with the HS code within the scope and subsequently replaced with identical packaging that is already placed on the market which is supporting, protecting, or carrying the product therein.

Request for Exclusion of Leather from Annex I of the EUDR To the European Commission, We, the undersigned stakeholders of the global leather industry, respectfully request the exclusion of leather from Annex I of the EU Deforestation Regulation (EUDR), effective December 30, 2025, for large companies.

As Beverage Industry Environmental Roundtable (BIER), we welcome the proposed clarifications to the scope of the EU Deforestation Regulation (2023/1115) as set out in the draft Delegated Regulation amending Annex I.

We ask the Commission to reassess the inclusion of bovine skin in the EUDR Regulation. Skin is a co-product of the meat chain, not a primary commodity. Studies (e.g. SantAnna Superior School in Pisa) show that its production does not incentivise deforestation: the skin is recovered from animals already intended for food processing.

Filed in Italian · English published by the European Commission

The EU Anti-Deforestation Regulation (EUDR) is wrong to include bovine hides and skins (customs codes 4101, 4104, 4107) in Annex I as drivers of deforestation. Wrong because it considers cattle as if they were reared in order to use their skin as a primary good.

Filed in Italian · English published by the European Commission

Assogomma is the Italian National Association representing the producers of tyres, rubber products, electric cables and the like. It involves over 200 companies, with around 30.000 employees and an estimated annual turnover of EUR 6 billion.

Filed in Italian · English published by the European Commission

The instructions for when a DDS are supposed to be made in Traces raises questions on the traceability and also the number of DDS that needs to be made. As a medium-sized company it is possible to re-use the supplier's DDS for both export and re-import. Then it easy to follow products way through the supply chain.

Federation of the Printing Industry in Finland suggests extending the definition of accessory materials to information materials in order not to limit the definition to only marketing products and excluding from the scope products that are accompanying a service or distributed for information purposes.

JTI stands behind the aim of preventing deforestation and forest degradation, as set out in the EU Deforestation Regulation. Ensuring a sustainable wood supply and contributing to conserving and rehabilitating forests are key objectives set out in the JT Group Sustainability Targets.

Clarification on placing on the market Article 2(16) of Regulation (EU) 2023/1115: The submission of the due diligence statement refers to relevant products or the assigned customs combined nomenclature (CN). Document C/2024/6789 can be misunderstood.

Filed in German · English published by the European Commission

In the context of HS code classification related to rubber, the Malaysian Rubber Board (MRB) has proposed an amendment to HS Code 4015. To improve clarity regarding the scope of this code, it is suggested that the following statement be added: "Does not include products made from synthetic rubber." The purpose of this amendment is to clearly exclude synthetic rubber products from being classified under HS Code 4015.

Raw bovine skin is an animal by-product that inevitably results from the slaughter of livestock, which is reared exclusively for meat production. As a residual material in the food chain, it has very little commercial value, so that its existence has no impact on the dynamics of rearing and killing animals.

Filed in Italian · English published by the European Commission

The amendments put forward in this delegated act have the aims of introducing clarity and certainty for EU operators. However, there are still some omissions that are likely to put EU operators at a competitive disadvantage. Though coffee and many derived products are included in Annex I of the EUDR, there is still a significant section of coffee products that are excluded from the requirements.

Our views on the amendment of Annex I to the Deforestation Regulation Exclusion of Brochures and Information Linked to Companys Main Products. We are a non-SME operator and produce products that fall under CN-code 4418 and we are then subjected to Wood under EUDR.

The exclusion of samples is a welcome simplification. I believe there is perhaps a mistake or a contradiction regarding the inclusion of "bamboo, rattan and other materials of woody nature" in page 2, paragraph 3. I have a request regarding the case of sales of leather scraps: As part of our manufacturing processes, we have leather scraps.

I request the exclusion of bovine hides and skins (customs codes 4101-4104-4107) from Annex I of the EUDR. Bovine skin is a by-product (ABP) of the food chain that can in no way affect deforestation as its availability is an ancillary consequence of the slaughter of livestock, which is only reared for meat.

Filed in Italian · English published by the European Commission

Bovine hides and skins should be excluded from the EUDR.Regulation. Management costs would make the European tanning sector even less competitive compared to non-EU farms, causing economic, production and labour losses.

Filed in Italian · English published by the European Commission

The inclusion of bovine hides in the EU Deforestation Regulation (EUDR) could have several significant impacts on global trade dynamics: 1. Shift in Competitive Advantage Non-EU countries not subject to EUDR could gain a cost advantage, exporting leather goods into the EU without the same traceability or sustainability requirements.

The Federal Association of Print and Media (BVDM) welcomes the Commission’s intention to make the EUDR workable through simplification and supports the present draft. We are particularly positive about the clarification of the scope of packaging, as well as accompanying material and correspondence items. However, in our view, these wordings have so far been too narrow.

Filed in German · English published by the European Commission

Based on the Targeted Stakeholder Consultation Questionnaire on the Scope of Annex I, Submitted to the IEEP/EU Commission on 13/02/2025 NESTI DANTE SRL, is an Italian Soaps Manufacturer The produce soap with the traditional method of saponification in big cauldron using palm oli and oalm kernelate oil.

Bovine and Porcine hides are not a driver of deforestation, as it is a non-relevant by-product. To trace the origin will increase the number of hides and skins that end up in landfills will have serious environmental consequences, not to mention economic damage and job losses. The benefit of real leather has environmental advantages over synthetic alternatives like "vegan leather".

Imported and exported goods under the scope of EUDR for benchmarking purposes should not fall into the scope of EUDR since these are considered as samples for potential future customers with whom we have no contract currently or might never have, depending on the outcome of the benchmark.

In my view, bovine hides and skins (customs codes 4101, 4104, 4107) should be excluded from Annex I of the EUDR because: — the animals from which the hides come from, in almost all cases, change several holdings before they arrive at slaughter; farmers are often not equipped or do not have the necessary culture to provide the required data in the manner required; — the skin chain involves the following steps: animal…

Filed in Italian · English published by the European Commission

(1) it makes no sense to include hides and skins in the list of products subject to the European regulation, as it is a waste from the food industry (meat) that animals are not reared for skin but for meat. (2) tanning companies perform a service to recover/recycle a slaughter waste and are an example of a circular economy.

Filed in Italian · English published by the European Commission

The Irish Whiskey Association is the trade association representing the Irish Whiskey sector, and includes 47 Irish Whiskey producers in its membership, from multinational spirits companies to craft distillers. The Irish Whiskey Association welcomes the clarification offered in the Annex under point (ee), which specifies the following the entry 4416 Casks, barrels, vats, tubs and other coopers products and parts…

— Bovine skin is waste from the slaughtering industry and therefore tanneries are to be considered waste recovery/recycling companies that would otherwise have to be disposed of as waste. As a result, the skin cannot be considered a driver for deforestation, at the very least the food meat industry can be considered as a driver (cattle are reared for meat and not for skin).

Filed in Italian · English published by the European Commission

I would like to agree with all the other comments confirming that the material relating to CoD 4101, 4104 and 4107 is not a raw material intended for cattle farming. More generally, even if this clear concept was not taken up by the Committee just as political opportunities, I can generally say that the methodology chosen by politics and committees of various luxtures, to introduce purely bureaucratic regulations…

Filed in Italian · English published by the European Commission

Our holding considers that bovine hides and skins (customs codes 4101, 4104, 4107) should be excluded from Annex I to the EUDR because raw bovine skin is an animal by-product (ABP), the availability of which is an ancillary consequence of the slaughter of livestock, reared only for meat.

Filed in Italian · English published by the European Commission

Our company considers that the exclusion of bovine hides and skins (customs codes 4101, 4104, 4107) from Annex I of the EUDR is necessary because raw bovine skin is an animal by-product (ABP) and is therefore only an ancillary consequence of the slaughter of livestock (reared only for meat). There is a food production gap altogether, and the value is so low that it has no influence on breeding costs and slaughter.

Filed in Italian · English published by the European Commission

From Hosokawa Alpine AG, we would like to make use of the opportunity to comment on the draft delegated act amending Annex I to Regulation (EU) 2023/1115 (EUDR) (Ares(2025)3099313, in the following draft). We welcome the proposed exemption for products for testing purposes from the requirements of the EUDR under Article 1 of the draft in conjunction with. Paragraph 1 of the Annex and sees our specific case.

Filed in German · English published by the European Commission

We recommend excluding oleochemicals and downstream palm-based derivatives from the scope of EUDR requirements. Initially, Annex 1 of the regulation targeted broad commodity categories such as palm, soy, coffee, and cattle. Palm oleochemicals were not part of this original list but were included at a later stage.

Raw bovine skin is classifiable as an animal by-product (ABP), the availability of which is closely linked to the slaughter of livestock, primarily reared for meat production. In this context, skin is an inevitable gap in the food supply chain.

Filed in Italian · English published by the European Commission

We appreciate the opportunity to provide feedback on the proposed revision of Annex I of Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR). We would like to highlight a contradiction in the formulations regarding rattan, bamboo, etc., between the two documents published in the consultation.

The various products included in Annex I to the EUDR (Regulation (EC) (EU) 2023/1115) include bovine skin, which we consider appropriate, since cattle farming is not intended to obtain the skin but to produce meat and milk for the food industry.

Filed in Italian · English published by the European Commission

(1) There is a mistake in recital 3: In addition, it is necessary to clarify that the relevant products listed under Wood in Annex I to Regulation (EU) 2023/1115 d o n t fall within the scope of that Regulation if they are made solely of bamboo, rattan, and other materials of woody nature. (2) Tree bark is not wood and therefore not a relevant commodity.

From a tyre retreading point of view the Q&A that have been published with the new Q&A 2.8.1 seems clear in its content. But FAQs does not bind legally. To avoid any misinterpretations, Annex I of EUDR should be clarified and show that used tyres and tyre casings/ carcasses should be out of the scope.

Thank you for the opportunity to provide feedback. We are a producer of wooden prefabricated houses (tariff No 9406). According to the latest edition of Annex 1, we are obliged to use the EUDR. The problem is that we are at the very end of supply chains and have the same deadlines as those at the very beginning of the supply chains.

Filed in German · English published by the European Commission

AIRP - Associazione Italiana Ricostruttori Pneumatici (Italian Tyre Retreaders Association) represents the independent Italian tyre retreading industry. Our association reports that already at the time of publication of Regulation (EU) 2023/1115, a strong concern had emerged in all companies in the retreading sector regarding the possible obligation to issue a due diligence statement relating to the carcasses to be…

Summary of Our Feedback Response to the Public Stakeholder Consultation Regarding the EU Regulation on Deforestation-Free Supply Chains Based on the Targeted Stakeholder Consultation Questionnaire on the Scope of Annex I, Submitted to the IEEP/EU Commission on 13/02/2025 Papoutsanis S.A., is a leading European integrated manufacturer of soaps in Greece.

The Committee of European Sugar Users (CIUS), representing major sugar-using food and drink companies in the European Union, welcomes the opportunity to provide feedback on the draft delegated act revising Annex I of the EU Deforestation Regulation (EUDR). We welcome the fact that sugarcane remains outside the scope of the Regulation in the proposed amendment.

Kappus 1848 GmbH, is a leading European manufacturer of solid soaps in Germany. As a supplier for the largest retail and drugstore chains in Europe, our production relies on palm oil and palm kernel oil. We support the objectives of the EUDR and its mission to reduce deforestation through more sustainable supply chains. We would like to raise two key concerns in current form. 1.

Tanned bovine skin (code dog. (41079910) it is a by-product and/or waste from the food chain, it has no sense to include it in the list of commodities that are drivers of deforestation. If it remains within the EUDR Regulation, it will lead to economic challenges at European level as non-EU countries will prefer to find less performing economies in other countries in order to fail to fulfil their obligations under…

Filed in Italian · English published by the European Commission

Regarding the following extract of the Annex of the draft Delegated Act: In the column, Relevant products, table note (1) is added after the entry Relevant Product: This Regulation does not apply to: a) Samples of products, which are of negligible value and quantity and can be consumed or used only to solicit orders for goods of the type they represent under the condition that the manner of presentation and…

As administrator of Al-Qaede Pneus, a Portuguese company with extensive experience in the retreading sector, I would like to express my concerns regarding the current wording of the proposal for a Delegated Regulation amending Annex I to Regulation (EU) 2023/1115.

Filed in Portuguese · English published by the European Commission

Please note: Due to the fact that the feedback given here cannot be formated please look at the attached document for a better understanding of the feedback. BIPAVER, representing the independent European Retreading and Tyre Trade Industry, welcomes the intention of the European Commission to clarify the EUDR regulation regarding its application to used and retreaded tyres.

We are worried about the retreading industry and the recycling aspects. It should be clearly stated that the tyre casings and carcasses and also the used tires should be out of scope. The recently published FAQ is clearly an improvement but not legally binding.

Dear Sir/Madam, As a logistics provider for an electronics company, we import mobile phones and the associated packaging material (cardboard boxes) separately. This approach was chosen to make transport more efficient and reduce energy consumption, as pre-packaged phones take up significantly more space during transport compared to separate shipments of equipment and flat-folded boxes.

Having read the drafted act and its annex, we would suggest the rewording of the last sentence of recital (3) on page 2 as follows: In addition, it is necessary to clarify that the relevant products listed under Wood in Annex I of Regulation (EU) 2023/1115 do not fall within the scope of that Regulation if they are made exclusively of bamboo, rattan and other materials of an apparently ligneous nature, but other…

Dear EU Commission, I would like to submit feedback regarding the application of the EUDR to coffee samples. We seek further clarification on this point, as it remains unclear whether a full DDS must be provided for each sample.

The first amendmento of Annex I concenrs the exclusion from "Relevant products" (This Regulation does not apply to). This will give a great help to the company receiving samples to be used for examination, analysis or tests.

Where is evidence based policy - This represents a disproportionate requirements that is too complex, too costly and may deliver very little environmental impact. Firstly, the EUDR needs a significant rethink on the breakdown of its categories.

We are an Italian roasting and have put in place a system of tracking and compliance with the EUDR regulation. What is not clear to us is how to proceed with the finished product (roasted coffee). On roasted coffee packs made of, for example, 3 raw materials imported from 3 different countries and for which 3 separate DDS (DDS 1, DDS 2 and DDS 3) have been presented, can all 3 DDS be included or a new DDS (DDS 4)…

Filed in Italian · English published by the European Commission

As an international acting non SME company we have still following questions / remarks regarding the EUDR: 1. currently there is only one HS code for rubber. It would be good to have a clear difference between synthetic rubber and natural rubber to easier split between EUDR effected and non effected parts 2.

Regulation (EU) 2023/1115 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 31 May 2023 on the making available on the Union market as well as export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 was published in a very different commercial context than today.

Filed in Spanish · English published by the European Commission

We welcome the initiative of the European Commission and the opportunity to participate in the consultation process regarding the proposal of Regulation (EU) 2023/1115 (EU Deforestation Regulation). As a responsible manufacturer, we fully support the initiative, which is to protect the environment by aiming to minimise the Unions contribution to deforestation and forest degradation.

Wooden packing material used for exporting other goods produced explicitly for export, thus neither placed on the market yet nor to be placed on the common market, to date, from the requirement to present a due diligence certificate, havent been excluded by the actual EU Deforestation Regulation nor by the actually proposed amendment of EUDR Annex I.

While the proposed amendment provides clarity in some specific products linked to the regulation, some "other" non-specified categories have not been clarified, such as "ex 4016 Other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40" which covers a variety of minimum quantity of product, while some categories of HS Code 40 in Rubber section is still not covered.

At Gemar, a family-owned and family-run business based in Casalvieri, we make more than balloons, we make moments. Our mission is to inspire and bring balloon joy to every occasion. As a manufacturer based in Italy producing latex balloons, we fully support the objectives of the EU Deforestation Regulation (EUDR), particularly the goal of minimizing the EUs contribution to deforestation and forest degradation…

While reviewing both uploaded documents regarding the amendments, I noticed what appears to be a discrepancy between the two texts. In the draft of the delegated regulation (page 2), it states:"The relevant products listed under Wood in Annex I to Regulation (EU) 2023/1115 do fall within the scope of that Regulation if they are made solely of bamboo, rattan, and other materials of woody nature." However, in the…

In my opinion, in Canary Islands Archipelago, 99% of goods made of timber or forestry productions arrive by ship to main ports, and customs authorities are first of knowing what things are inside containers, before crossing border and entry in UE.

We note a simplification effort proposed by the Commission, which unfortunately does not affect small businesses and small owners, which represent a significant part of the European forest-based industry. This will surely lead to segregation within the sector, favouring large companies and owners over smaller ones. It is therefore important that the Commission revise its proposal by incorporating this fact.

Filed in French · English published by the European Commission

1. Yesterday’s training of the EUDR database on the generation of the due diligence number is very poor. And this is still very much understated. This database was developed by someone who has no understanding of the subject matter. ZERO! I even say that the responsible person is a total failure in terms of computer literacy.

Filed in German · English published by the European Commission

We are an SME Operator in paper industry (small non integrated paper mill <30 ktons). Despite the exemptions for SMEs large costomers force us to supply ref.nr. with each delivery. If we don't fulfill these requests, clients threaten us to change suppliers. We use a fifo method on our pulp stock and have not ablity in our software system (SAP) to introduce a raw material charge management without substantial cost.

Is it possible that reason 3 for the amendment ("In addition, it is necessary to clarify that the relevant products listed under Wood in Annex I to Regulation (EU) 2023/1115 do fall within the scope of that Regulation if they are made solely of bamboo, rattan, and other materials of woody nature.") contradicts the actual amendment 3 in the Annex ("In the column, Relevant commodity, table note (2) is added after the…

As far as we have discussed the implementation of EUDR with our European partners, there is no clear understanding of the obligations under the Regulation. None of our Italian, Polish, Dutch, Belgian partners are ready to provide us with the relevant documentation as they do not gather and provide such at this point. Surprisingly, our Chinese partners have already taken steps to provide whatever data is necessary.

If we conduct due diligence on wooden cutlery (HS code: 4419) made from timber sourced from national and natural forests, do we verify legal compliance and ESG-related matters with national authorities? To harvest and use this timber as raw material, the national government issues logging permits to local authorities.

Recital (3) of the draft Delegated Regulation states that products made solely from bamboo, rattan and other woody materials "do fall" within the scope of the EUDR. However, Annex I of the EUDR is amended by para (3) of the Annex to read as follows: This Regulation does not apply to bamboo, rattan and other materials of a woody nature and therefore it does also not apply to relevant products listed under the…