GRSB Updates for March 6, 2024

I was in Paris from 21st to 23rd February for an OECD meeting covering the apparel industry. The specific panel I was asked to participate in covered leather, and deforestation-free compliance.

You have heard about EUDR several times now, but for every producer, processor and trader who expects to import to or export from the European Union as of the beginning of 2025, you will hear about it even more often from now on. If you are involved in any such trade, you are doubtless already aware of this.

The regulation is to ensure that there has been no deforestation associated with a range of products for sale in, or exported from Europe. This includes beef, offal, hides, skins and leather. The other commodities covered are Timber, Palm Oil, Soy, Rubber, Cocoa and Coffee and anything derived from them, so for example chocolate and foods containing it, instant coffee, tyres and any clothing containing rubber, oil cake and meals, husks (full list in the legislation).

Since this also includes such things as used tyres, any export of those from Europe for recycling will become next to impossible.

Since there has to be a full segregated supply chain traceability associated with these products, every single farm that has cattle whose meat, offal or hides will pass into or out of Europe is included under this legislation, as are all of the processors and other companies through whose hands these products pass.

Clearly, although milk products are not included in the legislation, dairy farms are because their offspring and cull cows are part of the meat and leather value chains.

Although countries will be categorised according to risk of deforestation, that does not change the due diligence requirements, but only the frequency with which checks will take place. Thus EU states themselves must also comply with this, as well as countries such as Uruguay where forest cover has increased by 153% since the 1990s (largely through planting of exotic species such as Eucalyptus).

As it happens, EU countries already have traceability back to farm of origin associated with cattle passports, and Uruguay has a similarly comprehensive system. For those countries the main challenge may be offal and hides, which are covered by the regulation.

The complexity of complying with this should not be underestimated. Typically hides and offal are not identified or traceable after slaughter, and both hides or meat / offal from large numbers of cattle from different sources are shipped together, with ground meat potentially containing meat from more than one country. Although mixed lots are allowed, they have to be segregated to contain only products from compliant farms, each of which has to be traceable through all life stages back to the farm of origin.

The costs of non-compliance are significant, with the potential for fines of up to 4% of EU turnover for any company found to be non-compliant, being applied to the company either placing such products on the EU market or exporting them from the EU. Such non-compliance would include having insufficient evidence of due diligence and traceability for the products concerned, whether or not it could be proven that there was deforestation associated with them.

The basis for deforestation in this case is a 2020 map created by the EU and a constantly updated version of the same. Any farm whose coordinates correspond with any deforestation (legal or illegal) since 2020 is automatically excluded from selling into or out of the EU. For the other commodities, the entire perimeter of plots growing the crops have to be given. For beef and hides, it is a coordinate representing the “establishment” (farm, ranch, feedlot etc. ) at which the cattle were kept.

That clearly raises questions of its own, since a single coordinate cannot realistically tell one anything about deforestation; one would need a cross reference to a list of known establishments with deforestation on them to infer whether an establishment was deforestation-free, and that does not exist for Europe or, indeed, for many other countries. There is also a question about whether the maps are capable of distinguishing between deforestation of native forests and felling of plantation forest for timber.

The EU has also said that they may add to this any form of land conversion in the future, e.g. any wooded land or even grasslands converted to crops etc.

If you are potentially affected I do recommend that you download and read the entire regulation here and visit this site and the FAQ at the bottom of the page for further explanatory information.

I know that many of those affected by this are not yet, and may still not be, fully prepared for it when the regulations are applied as of 1st January 2025. We want GRSB to play as much of a role as we can in helping members to prepare, and therefore would start with a series of calls, leading up to in-person workshops.

Part of this will involve engaging in a process with ISEAL which will cover all the commodities and share experience between platforms, such as the other commodity roundtables. Please contact myself and Josefina to share any relevant information, questions etc and register interest in getting involved in this.

Thank you, 

Ruaraidh Petre
Global Roundtable for Sustainable Beef
Executive Director
06 March 2024

Europe's new regulation for deforestation-free products, as I have written about in other GRSB Connects, has generated a great stir in the meat and leather export sector in the Latin American region.

They began by completely rejecting the law, alleging problems of national sovereignty and unfair market rules, as well as the costs and complications of implementing an environmental traceability system.

The national systems for recording production data and laws of producing countries are not easy to modify in the short term in order to adapt to these requirements.

Work is underway on adapting. There have been endless meetings with the Ministries of the Environment, Health and Agriculture to seek public-private solutions. I believe that is a great advance.

Personally, I believe that traceability is always important. It generates transparency, the fundamental data needed to analyze any business and many other key benefits. However, the transition to absolute traceability is causing a great revolution in the world of commodities impacted by the law.

We have known for a long time that this regulation was coming. In the world of meat and soy, to which I am closest, the progress that has been made since the law started to be discussed and then approved should not be a surprise.

At GRSB, we have had webinars about it, have written about it for GRSB Connect and have had many discussions in the Nature Positive Working Group. Now this has become a reality and the time to implement it has already begun, with only 10 months left.

As a Global Sustainable Meat Table, we have an important role to play. Our first consideration should be to inform and ensure we are all on the same level of understanding of the law and its interpretations.

We want GRSB to be an organization where you can bring us your doubts or questions. I believe we have a voice representing the chain across different venues. It is important that we bring relevant points to the authorities to help with the needs European importers or foreign exporters may have.

That is why we are part of the regular meetings of the European Commission (Commission/Multi-stakeholder Platform on the Protection and Restoration of the World's Forests, including the EU Timber Regulation and the FLEGT Regulation) and other similar arenas.

I think we have another role, besides informing. We have the role of facilitators and coordinators of sectoral projects. This is very important, as there are actions that the industry cannot do individually but require sectoral coordination for the chain as a whole.

We have been approached with and are discussing projects and needs that some have, but we need to prioritize needs to focus even on topics that no one is working on yet. I would like to invite you to bring these kinds of requests to us, and look for an ally in GRSB to finish unblocking your difficulty.

We invite you to participate in the next webinar on March 21, where we will bring different voices and interesting discussions about the next steps with EUDR.

Thank you,

Josefina Eisele
Global Roundtable for Sustainable Beef
Regional Director for Latin America 
06 March 2024


EUDR legislation was enacted last year and will become operational as of the beginning of 2025. The purpose of the legislation is to exclude commodities from the EU market that have contributed to deforestation or that were illegally produced in the country of origin.

This webinar will discuss the requirements of EUDR including due diligence, information requirements and risk assessment / mitigation. We will ask the audience what GRSB can be doing, in the time left, to assist our members in complying with the legislation to trade into or out of the EU.

This 90-minute webinar is an exclusive GRSB member benefit. Please choose Session 1 or Session 2 and click on the REGISTER HERE button below to register. There will be opportunities for all participants to ask questions and to join in the discussion.

This session will feature English to Spanish simultaneous translation.


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