The European Union approved a new EU Regulation on Deforestation and Forest Degradation (EUDR) in 2023, imposing strict restrictions on products that cause deforestation and on business processes that may negatively impact forests. For Ukrainian enterprises exporting products to the EU market, the implementation of this regulation will present a significant challenge, as they must adapt their operations to the new conditions.

 

Key Requirements of EUDR

According to the EUDR, any product imported into the EU must be “deforestation-free,” meaning that deforestation for the production of such goods must not have occurred after December 31, 2020.

 

Key requirements of EUDR include:

• Geolocation Accuracy: All operators must provide geolocation accurate to six digits of the plots of land where the relevant products are produced.
• Due Diligence Documentation: Producers must provide evidence that their goods comply with environmental standards and the legislation of the producing country.
• Data Reliability: Given the high level of corruption in Ukraine, European regulatory bodies will require additional proof of the legal origin of the products.

 

Current Issues for Ukraine

Ukrainian enterprises, especially in the forestry and agricultural sectors, may face the following challenges:

• Deforestation and Forest Degradation: Ukraine has vast areas of self-seeded forests that are not always officially registered, which may cause difficulties in product certification.
• Identification Problems with Forest Plots: The lack of proper forest accounting and the failure to allocate some of these for use lead to attempts at illegal logging.
• Improper Regulation of Logging: Uncertainty in logging rules and ambiguous interpretations of legislation also pose obstacles to achieving “low-risk” status.

 

Recommendations for Businesses

To comply with the EUDR requirements, Ukrainian companies should:

• Reform Their Production Processes: It is essential to ensure that only legal and environmentally friendly methods of raw material procurement are used. For example, enterprises should avoid using wood from self-seeded forests or from plots that have not undergone proper identification.
• Prepare Due Diligence Documentation: Operators must be ready to provide all necessary documentation regarding the origin of the products, including certificates confirming the environmental integrity of the goods.

 

On October 11, 2024, a working group meeting was held to facilitate Ukraine’s preparation for the implementation of the EU Regulation on Deforestation and Forest Degradation. Participants included stakeholders from Ukraine’s forestry sector, including the State Enterprise “Forests of Ukraine,” WWF Ukraine, FAO, FSC Ukraine, PEFC, IPRSA, the Ministry of Environmental Protection and Natural Resources of Ukraine, the State Forest Agency, business associations, and NGOs. Oksana Donska, a Board Member of the UAFM, participated in the meeting, stating, “It was a pleasure to engage in constructive dialogue where all participants aimed for a common goal—combating deforestation and forest degradation and managing forestry according to the norms and regulations accepted globally, particularly in the EU. The agenda included amending Ukrainian regulatory acts, adapting document flows to the requirements of the EUDR, and preparing businesses to operate under its requirements.”

To further explore the topic of EUDR implementation, we recommend watching the webinar we held in April:

 

And also the presentation materials from the working group participants:

 

Materials

 

Conclusion

Ukrainian enterprises planning to export their products to the EU must start preparing now to meet the EUDR requirements. This involves both legal and technological changes aimed at ensuring the ecological sustainability of their products. Companies that adapt to the new requirements will be able to maintain and expand their presence in the EU market, while those that do not take necessary steps risk losing access to this vital market.

 

Actions of the Ukrainian Association of Furniture Manufacturers (UAFM):

Since furniture manufacturers are purchasers of wood, and insufficient collaboration with suppliers may lead to a halt in the export of Ukrainian furniture containing wood, the UAM, together with the FPU and ADPU, sent a request to the Ministry of Environmental Protection and Natural Resources of Ukraine, asking it to instruct the State Forest Agency and the State Enterprise “Forests of Ukraine” to make necessary decisions and amend regulatory acts, documents, information systems, procedures, and regulations to provide wood purchasers with the following information and documents:

• The scientific name of the wood species.
• The country of logging.
• The geographical coordinates of all plots where logging occurred.
• The time or period of logging.
• Evidence of the legal procurement and processing of wood.
• Evidence that the procurement did not cause deforestation or degradation of forest plots.

 

Reference:

The EUDR (EU Regulation on Deforestation and Forest Degradation) is a new EU regulatory act aimed at combating deforestation and forest degradation caused by the production of agricultural and forestry products.

 

Key Aspects:

• Objective of the Regulation:
  • To protect forest ecosystems by prohibiting products that cause deforestation in EU markets.
  • To create conditions for sustainable production and use of forest resources.
• Products Subject to Regulation:
  • Timber and timber products.
  • Agricultural commodities: coffee, cocoa, rubber, soy, palm oil.
  • Cattle.
• Due Diligence Requirements:
  • Operators must ensure supply chain transparency, including geolocation of land plots where the products are grown.
  • All products must be deforestation-free after December 31, 2020.
  • Compliance with the legislation of the producing country is required.
• Challenges for Ukrainian Producers:
  • Difficulties in identifying land plots and self-seeded forests.
  • Imperfections in forest monitoring and logging systems.
  • Risk of product non-compliance due to high levels of corruption and inadequate forest resource accounting.
• Recommendations:
  • Use of geo-information systems for forest monitoring.
  • Improvement of the product origin certification process.
  • Activation of state reforms in forest protection and proper land accounting.
• Implementation Challenges:
  • Increasing the alignment of national legislation with EU requirements.
  • Ensuring transparency in product supply chains.
  • Supporting small producers in meeting new requirements.
• International Cooperation:
  • Stakeholder collaboration platforms, voluntary partnership agreements, technical assistance, and sharing best practices are crucial for the successful implementation of EUDR.