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MOTION FOR A RESOLUTION (2025/2739(RSP))

On 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)

B-10-2025-0321

Committee on the Environment, Climate and Food Safety · Rapporteur: Alexander Bernhuber

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Parliament considers that Commission Implementing Regulation (EU) 2025/1093 exceeds the implementing powers of Regulation (EU) 2023/1115 and calls for its repeal. It calls on the Commission to revise the country benchmarking system with up-to-date data, regional differentiation, transparent weighting, and clear reassessment procedures. It stresses inclusive engagement with producing countries and stakeholders, and calls for complementary measures like forest partnerships and technical assistance.

Key points

  1. The risk categorisation under Regulation (EU) 2023/1115 is based on outdated data and fails to reflect current realities, including land-use dynamics and forest degradation.
  2. The methodology ignores developments since 31 December 2020 and relies on data from the Global Forest Resources Assessment with submissions predating 2020.
  3. The methodology lacks transparency in weighting risk factors, does not account for regional variability, and focuses on aggregate historical deforestation rates.
  4. The current system lacks flexibility for timely updates and clear reassessment mechanisms, causing market uncertainty and misalignment with evolving conditions.
  5. The absence of pathways for countries to change risk categorisation through progress undermines the regulation's incentive role.
  6. The low-risk criterion of net forest loss between 2015 and 2020 includes temporary changes, and the thresholds of 0.2% or 70,000 hectares lack clear rationale.
  7. Using cropland expansion and overall wood production as proxies for deforestation risk is methodologically questionable.
  8. The three risk categories are insufficient; a fourth 'negligible risk' category should be considered for countries with robust frameworks and low land-use change.
  9. Static national classifications oversimplify risk and ignore regional progress or setbacks; a more adaptive, context-sensitive approach is needed.
  10. The model fails to account for commodity market volatility and should allow a regulated compensation mechanism outside primary or high-biodiversity areas.
  11. The benchmarking may disincentivise cooperation and lacks inclusive consultation with indigenous communities and local stakeholders.

Who is affected

  • Countries producing relevant commodities: risk categorisation affects their market access and due diligence obligations.
  • Indigenous communities and local stakeholders: need inclusive consultation in benchmarking.
  • The Commission: called to repeal and revise the implementing regulation.

Figures and deadlines

  • 0.2% annual forest area loss threshold
  • 70,000 hectares of annual forest loss threshold
  • 31 December 2020 cut-off date