The EACB welcomes the opportunity to participate in the European Commission’s consultation regarding its proposal to amend and simplify the rules and make technical fixes to Annex I of the EU Deforestation Regulation.
We appreciate the clarifications and simplifications already introduced in the level 1 text as part of the European Commission’s efforts to streamline regulation and alleviate undue burdens on market players. However, further refinement may be warranted to preserve the simplifications introduced. For instance, the EACB invites the Commission to further clarify that standard correspondence, marketing and informational materials, including those distributed free of charge and not intended to be placed on the market as standalone products, fall outside the scope of Annex I.
The EACB remains committed to the objectives of the EU Deforestation Regulation and stands ready to engage constructively with the European Commission to ensure its effective and proportionate application.