At a Glance
#1 India EUDR Stakeholder meeting
#2 Interview with Daniel from Tropical Forest Alliance
#3 EU resists calls to delay EUDR
#4 All change at the EU Environment Commission
#5 Role of Authorised Representatives
#Bonus Quick fact of the month
#1 India EUDR Stakeholder meeting
The Dilify team had the pleasure of being invited by the Rubber Board of India to attend a EUDR stakeholder workshop at the Indian Institute of Plantation Management (IIPM) to discuss all things EUDR related.
Our main takeaways were:
- Dr. S. Sudha, a Professor from the IIPM, provided a fantastic presentation about the levels of deforestation within Indian Rubber as well as import and export insight across the various HS codes in scope of EUDR. Some of the key insights are:
- In some regions of India such as Kerala, there is actually a Net Gain in terms of Forest coverage which is fantastic to see.
- India is the 6th largest producer globally of Natural Rubber
- India tyre exports increased by 12% in 2023-24
- More than 50% of India’s rubber exports are to the EU and the US
- The main challenges raised were gathering the geolocation data from the 1.2 million smallholder farmers in the country
- IIPM recommends an Indian Sustainable Natural Rubber certification from the Rubber Board to support EUDR compliance
- We presented our solution to the room of tire and non-tire manufacturers with some great feedback from the audience. We were enthused by the high levels of engagement from the audience, from tire manufacturers, to planters, to manufacturers which showed the positive momentum that India is making in regards to EUDR compliance
- Collective action is required to support the transitional work for Indian Rubber (and Coffee) - from government, associations, NGOs, software vendors, and private enterprises to make this a success.
- Finally, there is still clarity required from the EU on a number of items, especially in terms of the risk rating of India and its regions, which the government needs to discuss with the EU to ensure that there is an accurate risk classification of the country when the EU releases its country benchmarking system.
Overall, we enjoyed the workshop and will continue to support the work from the Rubber board to help accelerate the adoption of EUDR compliance processes for Indian Rubber businesses. More to come from this!
#2 Interview with Daniel from Tropical Forest Alliance
We recently had the pleasure of interviewing Daniel Kazimierski from the Tropical Forest Alliance about his contribution to the first EUDR compliant Soy shipment from Argentina which received great plaudits across the world.
1. Introduction and current role
Daniel Kazimierski works at the Tropical Forest Alliance (TFA) as the Argentina Coordinator, and brings a decade of experience in the soy industry with him, focusing on certification schemes and multi-stakeholder initiatives. In his current role, he leads the Chaco program in Argentina working with the soy and beef sectors to address deforestation and providing support in the design and implementation of public policies, public-private alliances and innovative financial mechanisms.
2. What is the VISEC Platform?
VISEC is a social and environmental platform, formed in 2019 as a private initiative. It's a collaboration between various stakeholders from the soy value chain, including CIARA-CEC, Peterson consultancy, The Nature Conservancy, and TFA who are part of the Secretariat. The platform aims to promote sustainable practices, transparency, and traceability in the soy and beef value chains. In response to the EUDR, VISEC has been working to develop systems and processes to ensure compliance for the soy sector initially, positioning itself as one of the most advanced initiatives in Argentina and across the world in meeting the EUDR requirements.
3. First EUDR Soy Shipment
In 2023, VISEC began developing an IT system with funding from various sources, including the European Union in 2024. VISEC conducted pilots in late 2023 and early 2024 to test information flows and system functionality. As a result, Argentina has successfully delivered more than four shipments of deforestation-free soymeal to Europe, involving different actors and supply chain complexities. These shipments have tested various scenarios, including direct and indirect supply chains, to ensure the system's adaptability to different commercial arrangements.
4. Main challenges with EUDR compliance
Argentina has all the capacity to apply technological solutions and collect credible information around traceability and good agricultural practices. The main challenge was shifting the mindset of actors towards collective action and developing an integral solution instead of individual approaches. This required aligning various stakeholders and developing a governance structure that could adapt to different situations. Their efforts now are also focus on in the implementation of a sensitisation program for producers and cooperatives throughout the country, strengthening knowledge about EUDR and the solution that is being developed by VISEC.
5. EUDR Compliance Advice
Daniel emphasised that while each country and commodity has its particularities, there are valuable lessons from the VISEC experience. Key advice he would provide is:
- Ensure the right actors are involved with clearly defined roles
- Build credibility and trust among partners
- Establish strong communication channels
- Consider involving NGOs, industry chambers, and trusted institutions to manage the process
- Recognise and manage different interests while working towards a single, collective solution
Thanks to Daniel for his time and dedication to supporting EUDR compliance for his sector - we look forward to many more EUDR-compliant shipments in the future!
#3 EU resists calls to delay EUDR
Political and Industry voices on both sides of the aisle are starting to grow louder with each passing month as the EUDR deadline approaches. The recent article in Reuters noted Mr Virginijus Sinkevicius is not considering a delay to the legislation. However, there is growing pressure to release the latest iteration of the guidance documents and to make the IT system available for Operators to utilise to produce due diligence statements.
#4 All change at the EU Environment Commission
Some big political news out of the European Union where long-standing EU environment commissioner Mr Virginijus Sinkevicius, who has been the driving force for the EU green deal and EUDR globally, has been elected to take a seat at the European Parliament, resigning from his current position. His responsibilities have temporarily assigned Executive Vice President Maroš Šefčovič to continue his work in the interim. We’ll monitor these developments closely as we approach the deadline at the end of the year.
#5 Role of Authorised Representatives
We recently had a few questions related to the role of Authorised Representatives in the context of submitting due diligence statements on behalf of EU operators and traders.
There are a few points to note if we are mandated to become an Authorised Representative on your company’s behalf:
- Once the EU Operator or Trader is registered on the EU Information System, they also need to include their EORI (Economic Operators Registration and Identification) number in the registration of their profile
- The EU Operator or Trader must provide a written mandate to their Authorised Representative to enable them to act on behalf of the importer
- The Authorised representative must make a written copy of the mandate available should their competent authority request this
- Key to note that the EU Operator or Trader will retain responsibility for the compliance of the relevant products
- If the EU operator is a natural person or micro-enterprise, it may mandate the next operator or trader in the supply chain to act as its authorised representative
Quick fact of the month
Did you know that recycled materials are exempt from EUDR?
The guidance notes explicitly state that the: