The European Association of Co-operative Banks supports the environmental goals of the EU Deforestation Regulation but highlights the need for clearer and adequate rules. While simplification of the Regulation is welcome, key concerns remain, including ambiguity around which products and activities fall within scope, some of which should be explicitly excluded to avoid unnecessary administrative burden.
The EACB also calls for the Regulation to properly account for group and cooperative network structures, ensuring that intra-group activities do not trigger duplicative due-diligence and reporting requirements. Additionally, introducing a well-calibrated de-minimis threshold would help ensure compliance efforts focus on areas with meaningful environmental impact.
EACB members encourage co-legislators to simplify and clarify the Regulation in the ongoing legislative process, and to ensure consistency with other EU sustainability frameworks, so that the EUDR can effectively achieve its goal of reducing global deforestation.