Source: European Parliament
The European Parliament,
– having regard to Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 laying down rules for the application of Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards a list of countries that present a low or high risk of producing relevant commodities for which the relevant products do not comply with Article 3, point (a)(1),
– having regard to Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010(2), and in particular Article 29(2) thereof,
– having regard to Article 11 of Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission’s exercise of implementing powers(3),
– having regard to Rule 115(2) and (3) of its Rules of Procedure,
– having regard to the motion for a resolution of the Committee on the Environment, Climate and Food Safety,
– having regard to the plenary vote of the European Parliament of 14 November 2024 on the Regulation amending Regulation (EU) 2023/1115 as regards provisions relating to the date of application,
Concerns about data quality and methodological robustness
A. whereas the proposed risk categorisation of countries under Regulation (EU) 2023/1115 does not accurately reflect the current realities in the countries concerned, as it is based on outdated data and fails to incorporate all relevant and available risk indicators;
B. whereas Commission Implementing Regulation (EU) 2025/1093 does not accurately reflect realities in the countries concerned as it fails to consider key real-world factors, most notably current land-use dynamics and forest degradation; whereas recognising degradation as a risk factor would result in certain Member States being placed in higher risk categories, thereby challenging the assumption that supply chains within the Union are automatically low-risk(4);
C. whereas key developments in governance, deforestation trends, and enforcement mechanisms that have occurred since 31 December 2020, which is the cut-off date referred to in Article 2 of Regulation (EU) 2023/1115, are not adequately reflected in the methodology;
D. whereas the data relied on for the risk categorisation are primarily derived from the Global Forest Resources Assessment carried out by the Food and Agricultural Organization of the United Nations, with the latest full-cycle country submissions predating 2020, and therefore such data do not adequately or fairly represent the recent national efforts to prevent deforestation, updated land-use policies, real-time satellite monitoring improvements and the latest deforestation trends in several countries(5);
E. whereas the methodology for the risk categorisation of countries lacks transparency in relation to how various risk factors are weighted and does not account for regional variability within countries; whereas this raises serious concerns about the fairness and credibility of the classification methodology;
F. whereas the methodology for the risk categorisation of countries is flawed because it focuses primarily on aggregate historical deforestation rates and this approach disregards the multidimensional nature of deforestation risk, failing to consider the full scope of indicators set out in Article 29 of Regulation (EU) 2023/1115;
G. whereas the approach underlying the current methodology established in Regulation (EU) 2023/1115 does not provide sufficient flexibility to accommodate timely updates, thereby creating significant market uncertainty and potential volatility;
H. whereas, without a clearly defined mechanism for regular and transparent reassessment, the classification of countries in risk categories becoming misaligned with evolving conditions, thereby undermining both the effectiveness of Regulation (EU) 2023/1115 and the functioning of global commodity markets;
I. whereas the absence of clear pathways for countries to have their risk categorisation changed through demonstrable progress undermines the role of Regulation (EU) 2023/1115 as a positive incentive mechanism and limits its potential to drive sustainable transformation on the ground;
Analysis of challenges in the first risk category of countries (the ‘category low risk’)
J. whereas the criterion of net forest loss between 2015 and 2020, used to determine the category low risk referred to in Article 29(1), point (b), of Regulation (EU) 2023/1115, considers total forest area loss rather than deforestation as narrowly defined under that Regulation, thereby including areas of temporary forest cover change or forest management not associated with land-use conversion, which undermines methodological consistency and legal certainty;
K. whereas the methodology for the for the risk categorisation of countries introduces a relative threshold of 0,2 % annual forest area loss, and an absolute threshold of 70 000 hectares of annual forest loss, without providing a clear rationale for those specific values; whereas it is noteworthy that certain high-deforestation countries, such as the United States, fall just below the absolute threshold, raising questions about the objectivity and robustness of the chosen benchmarks;
L. whereas the assessment of deforestation risk based on the expansion of cropland areas used for relevant commodities, as defined in Article 2, point (1), of Regulation (EU) 2023/1115, and the scale of livestock and wood production lacks precision; whereas the inclusion of overall wood production as a proxy for deforestation risks is methodologically questionable, as it conflates lawful forestry activities with deforestation driven by land-use change;
Lack of granularity and context sensitivity
M. whereas the current system of having only three risk categories is insufficient to adequately differentiate between countries with vastly different levels of deforestation risk;
N. whereas the lack of a nuanced approach could undermine the incentive for more ambitious governments to take further action, as it effectively penalises progress and fails to recognise meaningful efforts to combat deforestation;
O. whereas the Commission should address the methodological shortcomings of the current tripartite classification system by considering the introduction of a fourth risk category — ‘negligible risk’ — to reflect the reality that in certain countries or regions, the risk of deforestation or forest degradation is effectively negligible due to robust legal frameworks, low land-use change dynamics and sustainable land management practices;
P. whereas the current system risks oversimplifying deforestation risk by granting the status to countries based on outdated data or national averages, which could create a false sense of security and potentially reduce the due diligence obligation for products originating from areas where illegal deforestation persists;
Q. whereas, although the current data have shown a localised increase in deforestation in certain regions of the globe, such developments underscore the need for a granular, region-specific monitoring rather than static national risk classifications, which pose a risk of mischaracterising the overall trend and of ignoring regional progress or setbacks;
R. whereas credible research and long-term studies, such as ‘Deforestation in the Amazon: Past, Present and Future’(6) published by the Amazon Network of Georeferenced Socio-Environmental Information in 2023, demonstrate the complexity and variability of deforestation dynamics driven by political cycles, enforcement levels, and local socio-economic conditions, and therefore support the need for a more adaptive, context-sensitive approach rather than rigid country benchmarks;
S. whereas the current risk classification model fails to account for the volatility of global commodity markets, where price fluctuations, trade dynamics, and demand shifts can rapidly alter deforestation pressures;
T. whereas the risk classification should also allow for the creation of a regulated compensation mechanism, applicable exclusively outside of primary or high-biodiversity areas;
Concerns about fairness, legitimacy and global engagement
U. whereas the current country benchmarking system may disincentivise cooperation and data sharing by countries producing relevant commodities, particularly if they perceive the risk categorisation of countries as unfair or politically motivated; whereas fostering mutual trust and engagement requires a fair, evidence-based and collaborative approach that encourages transparency and accountability rather than punitive labelling;
V. whereas environmental and civil society organisations from countries producing relevant commodities have raised concerns about the lack of inclusive consultation in the development of the country benchmarking system, highlighting the importance of participatory processes that involve indigenous communities, local stakeholders, and regional authorities;
1. Considers that Implementing Regulation (EU) 2025/1093 exceeds the implementing powers provided for in Regulation (EU) 2023/1115;
2. Calls on the Commission to repeal Implementing Regulation (EU) 2025/1093;
3. Calls on the Commission to revise the country benchmarking system to ensure it is based on up-to-date data, allows for regional differentiation, and includes transparent weighting of risk indicators;
4. Urges the Commission to establish clear, time-bound, and transparent procedures for reassessing risk categorisation of countries regularly based on measurable progress and updated scientific data;
5. Stresses the importance of engaging with countries producing relevant commodities and stakeholders through inclusive and participatory processes, and of providing support for forest governance reforms and traceability systems;
6. Calls for complementary measures, such as forest partnerships, technical assistance, and fair trade incentives, to accompany the benchmarking process and promote sustainable transformation in commodity-producing regions;
7. Instructs its President to forward this resolution to the Council and the Commission, and to the governments and parliaments of the Member States.
| (1) |
OJ L, 2025/1093, 23.5.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/1093/oj. |
| (2) |
OJ L 150, 9.6.2023, p. 206, ELI: http://data.europa.eu/eli/reg/2023/1115/oj. |
| (3) |
OJ L 55, 28.2.2011, p. 13, ELI: http://data.europa.eu/eli/reg/2011/182/oj. |
| (4) |
https://www.eea.europa.eu/publications/how-are-european-forest/how-are-european-forest-ecosystems-doing. |
| (5) |
https://www.fao.org/forest-resources-assessment/en. |
| (6) |
https://infoamazonia.org/wp-content/uploads/2023/03/DEFORESTACION-AMAZONIA-2025_21032023.pdf. |
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