The EU Deforestation Regulation (EUDR) implementation must be workable, risk-based and enforceable in practice. Current uncertainty, particularly around Article 7 (‘deemed operators’), the definition of the true EU ‘first operator’ and the boundary between verification and liability, is driving market behaviour that cascades compliance burdens downstream, undermining simplification and increasing the risk of disruption.
At the same time, traceability and tool capacity remain the weakest links. Unresolved scenarios and uncertainty about system capacity at scale risk turning compliance into ‘tick-box’ documentation rather than effective deforestation risk mitigation.
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