EU must reconsider its deforestation law

In 2023, the European Union (EU) issued the European Union Deforestation-free Products Regulation (EUDR) as part of the comprehensive EU Green Deal.

The U.S. forest products industry fully supports the goal of deforestation-free supply chains and remains a strong proponent of international efforts to suppress deforestation and forest degradation.

However, EUDR as currently written imposes some unachievable requirements that create significant technical barriers for the U.S. forest products industry — which risks trade between the EU and the United States.

U.S. forest product exports to the EU are valued at more than $3.5 billion. The United States ships about 60 percent of the EU’s supply of specialty pulp that’s used to make things like diapers, menstrual and incontinence products.

The wood inputs used to make a single batch of pulp at a mill can come from multiple sources — known as a fiber flow.

This is why EUDR’s implementation process is of particular concern. This is especially true for the regulation’s strict geolocation traceability requirements that force producers to trace each product shipment to specific land plots using exact geographic coordinates. Exporters also must provide contact details for their supply chain partners as part of their due diligence.

The complexity of our industry’s supply chains, combined with sawmill leftovers and forest residues — which are frequently blended throughout production — make tracing each wood chip from its original forest plot to the final product becomes virtually impossible. Furthermore, the necessary technology to track this fiber flow does not currently exist.

EU manufacturers would not receive the supply of specialty pulp needed if U.S. pulp and paper manufacturers cannot overcome the technical barriers of the traceability requirement. This would cause significant trade disruptions between the United States and the EU and disrupt the EU marketplace.

We urge the European Commission to address the challenges the EUDR poses for the U.S. pulp and paper industry to prevent major trade disruptions. Delaying the regulation, as supported by the U.S. government in a May 30 letter from the U.S. Department of Agriculture, U.S. Trade Representative and the U.S. Department of Commerce, is a crucial first step.

A realistic solution that acknowledges United States sustainable forestry management is needed to help producers comply with the EUDR without disrupting trade. We will continue to advocate for balanced regulations and look forward to collaborating with EU regulators and stakeholders on EUDR implementation.

(Mark Pitts is executive director, Printing-Writing, Pulp and Tissue for the American Forest & Paper Association [AF&PA]. AF&PA’s membership consists of manufacturers of toilet paper, paper towels, boxes and packaging, paper bags, notebook paper and lumber that accounts for about 87 percent of the pulp, paper, paper-based packaging and tissue products made in the United States. It promotes safety and sustainability in the forest products industry. Find them online at afandpa.org.)