The European SINTETIC project is developed in the framework of the recently adopted EU regulation to combat deforestation. From 30 December 2024, the EU Deforestation Regulation (EUDR) will replace the EU Timber Regulation (EUTR) and it will oblige operators and traders of seven specific commodities, including timber, to apply a due diligence system prior to importing, exporting and/or placing these commodities on the EU Market.

Timber must come from plots of land where no deforestation or forest degradation has occurred, and operators must have documentation to prove the deforestation-free wood has been legally harvested before entering the EU market. Information as tree species, country of harvest, geo-coordinates of all plots of land where the wood was harvested, date or time range of harvest and evidence that the deforestation-free wood was legally harvested will be provided by operators and traders. Ensuring the truthfulness and precision of geolocation information is a crucial aspect of this new regulation.

The EU Deforestation Regulation in a nutshell

On 9 June 2023, Regulation (EU) 2023/1115 concerning the making available on the EU market and the export from the EU of certain commodities and products associated with deforestation and forest degradation (“Deforestation Regulation”) was published on the EU official Journal and entered into force on 29 June 2023.

From 30 December 2024 (or 30 June 2025 for micro or small businesses), it will be prohibited to place relevant products on the EU market, or export them from the EU, unless they are:

• deforestation-free, produced on land that has not been subject to deforestation (and forest degradation) after 31 december 2020
• produced in accordance with the relevant legislation of the country of production; and
• covered by a due diligence statement indicating no more than a negligible risk of non-compliance.

According to the level of risk assigned to each Country, operators will have to put in place one or three steps of due diligence:

• STEP 1 (As per Article 9). Collect information (and retain for 5 years) relating to: (i) the description of the covered products; (ii) their quantity; (iii) (parts of) the country of production; (iv) geo-localisation coordinates; (v) the name and contact details of their relevant suppliers and customers; and (vi) adequately conclusive and verifiable data that the covered products are deforestation-free and have been produced in accordance with the relevant legislation of the country of production.
• STEP 2 (As per Article 10) Operators must assess the risk of the products being non-compliant with the EUDR. Only if the risk assessment identifies no or only a negligible risk, may the product be placed (including imported) on the EU market or exported from the European Union. That risk assessment must be annually reviewed.
• STEP 3 Risk assessment. If no or non-negligible risk is found => adequate and proportionate risk mitigation measures must be taken before the products may be placed (including imported) on the EU market or exported from the EU. Available risk mitigation measures include implementing model risk management practices, reporting, and independent audits as well as appointing a compliance officer at management.

The geo-localisation requirement

The geographical location of a plot of land described by means of latitude and longitude coordinates corresponding to at least one latitude and one longitude point and using at least six decimal digits. The format of the geolocalisation information provided can differ according to the size of plots:

• For plot below 4 hectares, it is sufficient to provide one latitude and one longitude point,
• For plot above 4 hectares the geolocalisation information shall refer to the perimeter polygon identified by sufficient latitude and longiutude points.

Finally, the due diligence statements will be accessible to authorities, traders, and to a more limited extent, the general public. Companies who place relevant products on the market also have an obligation to communicate the reference numbers of due diligence statements down the supply chain, all information necessary to demonstrate that due diligence was performed, and that no more than a negligible risk was identified.