Transkrypcja: New EU Deforestation Regulation – navigating the requirements

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Hello everyone, my name is David Hadley and I am the director of the Referred by Nature's Regulatory Programme. In this life funded webinar recording we will be introducing the main elements of the EU deforestation regulation and requirements for European companies. So the objective of the webinar is to ensure listeners have a solid overview of the content of the regulation in relation to deforestation free commodities. So the webinar will last about 45 minutes during which we will introduce the regulation, discuss the main actors with obligations described in the regulation, cover the obligations on companies and due diligence requirements and provide a very quick overview of the checks and enforcement obligations of competent authorities in each of the member states.

Of course we cannot cover everything about the regulation during this time, it's quite a comprehensive regulation. The intention however is that the Referred by Nature will organise some additional future webinars via the LIFE project which will take a closer look at more specific topics. So let's start with an introduction to the regulation itself. The original proposal for a regulation on deforestation free commodities was published by the European Commission in November 2021. Within the regulation text itself the EU recognises that it is an important consumer region of forest risk commodities. It also expresses concern that deforestation is occurring at an alarming rate, aggravating climate change and the loss of biodiversity.

So this regulation serves as a flagship action if you like of the European Green Deal to reduce the EU's contribution to deforestation. For those not familiar with the European Green Deal it is just the set of policy initiatives that was published by the European Commission in 2019 and approved in 2020 with the overarching aim of making the EU climate neutral by 2050. Of course it is well known that a critical driver of deforestation and forest degradation is the expansion of agricultural land to produce commodities such as cattle, wood, palm oil and soy.

And by way of example a study published in September last year in the journal Science found that between 2011 and 2015 as much as 90% of deforested land occurred in tropical landscapes where agriculture directly or indirectly was driving that forest loss. So what is the status of the regulation? Over the last few months negotiations called the trialogue have been taking place between the European Commission, the Council of the European Union and the European Parliament over three different draft versions of the regulation. Agreement was reached on a single text or at least on major topics related to the regulation on the 6th of December 2022.

Discussions on finer details we understand have been continuing with the approval of the final text which is obviously not yet available expected sometime in the first quarter of 2023. The regulation will then be published in the official journal of the EU and enters into force 20 days after its publication in the journal. So timelines for implementation. Businesses will have 18 months from entry into force to comply with all requirements of the regulation. That's called the date of application. Small businesses and micro enterprises will have a little longer they'll have up they'll have two years 24 months.

18 months sounds like long enough but it is only the second half of next year for those familiar with other regulations such as the EU timber regulation which came into force in 2010. Companies have three years to prepare. So for the next two slides I just want to raise some points. Firstly I just mentioned that discussions on finer details are continuing. So with an approved final text still not available what is this presentation based on? It's based on the original three draft texts of the European Commission, Council and European Parliament.

Some press releases issued by those institutions since the 6th of December 2022 but also a version of the regulation a version of the regulation with the final compromise text included within it and endorsed by the permanent representatives committee sent by the council to the European Parliament for review and possible adoption and that text was made available on the 21st of December last year. So I guess just to say do I expect that what I discuss in this presentation will change much prior to finalization of the regulation? No. This presentation is very much at a higher level looking at the broad building blocks of the regulation and those will not change.

However you know it is possible that some of the finer grained detail of the regulation may change between now when we have the very final version of it. Secondly I mentioned the EU timber regulation or the EUTR for short. It's an important point for many listening to this recording that the regulation will replace the EU timber regulation or the EUTR which only addresses timber and wood products and not other agricultural commodities. There are similarities in relation to the due diligence functions and the obligations on businesses between the EUTR and the EU deforestation regulation but there are also some significant important differences. I will try to highlight some of those differences within this recording.

But just a final note for this slide as per articles 35 and 36 of the EU deforestation regulation. The EU timber regulation shall continue to apply to wood products for three years after the EUTR becomes applicable to businesses. Where trees were harvested before the deforestation regulation came into force but the products of those trees were placed on the EU market or exported on or after the deforestation regulation became applicable to businesses. So this slide is just intended to give sort of an overview of the regulation structure and content. There are four key components perhaps of the regulation. I'll go through those left to right.

Firstly a prohibition to place on the EU market or export from the EU products which contain, have been fed with or have been made using commodities which are not deforestation free or have not been produced in accordance with the relevant legislation in the country of production. Secondly there is a due diligence obligation, a requirement on businesses to exercise due diligence on their supply chains to ensure that the risks of deforestation or the risks of non-legally compliant production are low. Thirdly the regulation places a series of obligations on member states to ensure enforcement and implementation of the regulation.

And finally there's the establishment of what the regulation calls an information system which is a new development compared to the EU timber regulation and I'll talk a little bit about that later. But this recording will focus mostly on points one and two that you see here. So the following commodities are included within the scope of the regulation. Wood, beef, palm oil, soy, coffee, cocoa and rubber with some additional derived products from them such as leather from cows, chocolate and cocoa. These are considered to be by the EU to be of highest importance and impact in relation to deforestation risk and forest degradation.

Within each commodity the regulation defines which products are subject to the regulation according to EU customs codes. So within the regulation annex one basically lists the relevant customs codes applicable for each commodity. By default this means that any product or commodity imported or exported from the EU under a customs code which is not listed in the annex would be considered to be exempt from the regulation. So which products are included? Well in the case of cattle the scope of products includes live cattle, meat, offal and hides of various descriptions. In the case of cocoa it includes cocoa beans, paste, cocoa butter, cocoa oil, cocoa powder and of course chocolate as a derivative.

For coffee, coffee beans, husks and substitutes containing coffee. For soy, soybeans, soy flour, soy meal, soy oil and other residues. For oil palm, palm oil and its different stages of refining, palm nuts and kernels and interestingly some chemical derivatives of palm oil were also included that were not actually initially included in the three draft versions of the regulation. In the case of wood products the scope of products included in the deforestation regulation is effectively an expanded version of the scope of products included within the EU timber regulation. So that if you're not familiar with that regulation we're talking about most products containing paper, cardboard, wood chips or wood chips and wood chips and wood chips.

Containing paper, cardboard, wood chips or wood fibre or solid wood. It seems that the EU has revised upwards or expanded that scope of products to reflect the concerns of some civil society organisations and previous consultations on this topic. So the final text of the regulation seems to have basically combined additions to the scope of wood products both from the council and the European Parliament to include to have this finalised expanded list which includes some new additions such as printed materials basically all of chapter 49, charcoal products, other miscellaneous products formerly excluded such as tools, wood flour, wood wool, coffins and all types of seeds.

And finally in the case of rubber products have their resiliences natural rubber is included various forms of processed rubber including some products, tyres, rubber gloves and other articles of rubber used in apparel. So let's now look at who are the main actors with obligations described within the regulation. There are four. Firstly the European Commission. In terms of responsibilities the role of the European Commission is to define this regulation and subsequent implementing regulations and to provide guidance to ensure that the member states implement their obligations and to coordinate information sharing between member states. The Commission is also responsible for developing the information system and interface for the customs database.

Next in line each of the 27 member states have an important role to play. They will each designate a competent authority responsible for the overall enforcement of the regulation and develop detailed rules on penalties within their jurisdictions. Those competent authorities will be responsible for carrying out checks of operators. And in a new development compared to the EU timber regulation customs authorities of the EU member states will have a much larger role to play in supporting enforcement and implementation of the regulation. They shall control the correct declarations of relevant products within scope of the regulation entering or leaving the EU market. Then finally we have businesses or private sector organisations.

These will include mostly operators on whom most of the responsibility falls in relation to the deforestation regulation and traders. For this presentation we will focus mostly on the obligations under the regulation for operators and traders. So an operator is an organisation that places commodities or products included within the scope of the regulation on the EU market for the first time in the course of a commercial activity. Or export those commodities or products from the EU market. The important addition here to this regulation is the mention of export if we compare it to the EU timber regulation.

Traders are defined in the regulation as those businesses which buy or sell products which have products which have effectively already been placed on the EU market for distribution, processing or consumption. This graphic just expresses those last two slides visually. Operators may be importers, customs clearing products onto the EU market, they may be exporters of products from the EU or if you look at the dashed red line, entities which are already based within the EU itself, placing products on the EU market for the first time. A final development or another development I should say in the regulation is authorised representatives. So the concept of monitoring organisations has appeared in the EU timber regulation has been removed.

Instead the regulation describes the role of authorised representatives. There's no description of what type of organisation an authorised representative might be. However, authorised representatives are really just any entity with a formal mandate from an organisation to provide a support function to them and to act on their behalf. So this legal figure appears in a range of different EU regulations and directives including the proposed EU corporate sustainability due diligence directive for example and others. In the case of the EU deforestation regulation, authorised representatives would mainly receive a mandate to submit due diligence statements on the behalf of an operator or trader.

But I guess in theory they could take on other aspects of compliance with the regulation such as conducting due diligence on the behalf of the operator or trader, evaluating risks and other activities. It is important however just to say that the regulation is very clear that operators or traders do retain responsibility and liability for compliance with the regulation in relation to their supply chains at all times, whether or not they are working with an authorised representative. So what are the obligations on traders and operators? So starting with operators, again the weight of responsibility lies on operators in terms of obligations in this regulation.

They may only place on the EU market or export from it products that are deforestation free and have been produced in accordance with the relevant legislation of the country of production. The operator must also have in place a due diligence system to avoid in its sourcing commodities or products which are associated with risks of non-legally compliant production or with deforestation. And finally all products placed on the EU market or exported from it must be covered by a due diligence statement which accompanies the import or export of that product. Obligations of traders depends on the size of the organisation which is acting as a trader.

Traders which are SMEs are required to keep information about their suppliers and customers to make traceability of products subject to the regulation easier. So they must collect and keep information on their buyers and suppliers and then they are required to make sure that the information is available to them. They must also keep information on their buyers and suppliers including reference numbers of the due diligence statements associated with the products that they're trading. They must keep information for at least five years and be prepared to share all of this information with competent authorities on request. However traders which are not SMEs are required to have obligations as an operator. This is extremely important for larger companies.

It means that they will be required to actually have in place a due diligence system and conduct full due diligence on all relevant commodities and products. So what is deforestation free? There are some important definitions in the regulation which implications for operators as well as the supply chains through which they're sourcing. Article 3 of the regulation requires that all products be deforestation free but how is that actually defined? Well it refers to products that contain, have been fed with or have been made using commodities which were produced on land that has not been subject to deforestation after the 31st of December 2020. So first comment is that that date effectively becomes a cutoff date for deforestation in the regulation.

Deforestation itself is defined as the conversion of forests to agricultural use whether human induced or not. So what are the implications of this? There are some points we could raise. Wood products for example derived from deforested land since that cutoff date or after the cutoff date but relating to say deforestation or conversion for other reasons than agriculture for example infrastructure development, new roads etc. would not be prohibited under the regulation. Also if we take that term have been fed with, so in relation to cattle fed with commodities, soy products placed on the EU market or exported from them would be subject to the prohibition if the soy was grown on recently deforested land.

Cattle products placed on the EU market or exported from it would be subject to the prohibition if cattle were raised on land which had been recently deforested. Additionally in the case of cattle feed or cattle fed I should say with a soy based feed, cattle are also subject to the prohibition if the soy used in the cattle feed has been grown on recently deforested land. So just a final point on the cutoff date, why the 31st of December 2020, that date really just aligns with the New York declaration on forests, a political declaration calling to end the loss and degradation of natural forests by 2030 and eliminating deforestation for production of agricultural commodities well before 2030.

So for wood products the definition of deforestation free includes additionally that the wood has been harvested without causing forest degradation also after December 31st 2020. What is that definition of deforestation, of forest degradation? Well interestingly this is one of the areas where the draft proposal, the draft texts of the regulation differed remarkably between the commission, the council and the European Parliament, however we seem to have a final definition, a final answer on how forest degradation is defined. Forest degradation means structural changes to forest cover taking the form of the conversion of primary forests or naturally regenerating forests into plantation forests or into other wooded land or the conversion of primary forests into planted forests.

So that definition itself requires reflection and time to interpret it, we don't have enough time to do that now. Suffice to say all words in green on the slide are defined broadly in line with FAO definitions. And a second point I guess we could conclude that the concept of degradation is being limited to the conversion of naturally regenerating forests whether of native tree species as in the primary forest or other forests composed of trees established through natural regeneration whether they're native species or not.

To either forests for which natural regeneration does now not occur or has been replaced by planting or to forests which are severely degraded to the point where they would be considered other wooded land. Other wooded land is defined as having a canopy cover between five and ten percent. So commodities must have been legally produced also. Legality is defined as compliance with relevant legislation in the country of production. Concerning the legal status of the area of production in terms of land use rights, environmental protection, forest related regulations including forest management, biodiversity conservation were directly related to harvesting.

Third parties rights, labor rights, human rights protected under international law, the principle of FPIC as well as tax anti-corruption trade and customs regulations. So like other regulations the EU avoids prescriptively naming specific laws or types of laws rather it describes buckets or categories of legislation as it's done here. It describes these eight different categories of legislation. So under for example labor rights we would imagine that will include all laws relating to for example the requirement for contracts and work permits, obligatory insurances, laws relating to certificates of competency, or other training requirements, compliance with minimum working age, compliance in relation to discrimination, forced or compulsory labor etc.

And it's on the part of the operator to define those types of laws which would be relevant to each of these broad categories. The list of categories, this list of eight categories of legislation is much longer than was originally proposed by the Commission. The final text to a great extent incorporates many of the amendments of both the Council of the European Union and the European Parliament. So this final version I guess of the EU deforestation regulation very much strengthens protections in relation to workplace and international human rights standards.

So just to summarize a little bit the last set of slides there is a slight difference between requirements for agricultural products and wood products, all products or commodities within the scope of the regulation must be produced in compliance with relevant legislation and have been produced on land that was not deforested after 31st of December 2020. Additionally wood products must have been harvested in compliance with relevant legislation and without having contributed to forest degradation after the 31st of December 2030, sorry 2020, my apologies.

So what are the requirements of the regulation in relation to conducting due diligence? Broadly the due diligence requirements of the deforestation regulation are similar in nature to other due diligence requirements described in other regulations such as the EU timber regulation. Prior to placing relevant products on the market or exporting them, operators must exercise due diligence with regards to all of the relevant commodities which comprise those products. However one important point relating to how operators report to authorities is that before placing a product that's covered by the regulation on the market or exporting it, operators must submit a due diligence statement through an online information system. This has to happen beforehand.

The due diligence statement provides basically an assurance from the operator that the product is negligible risk in relation to legal non-compliance and being deforestation free. And submitting this due diligence statement basically with the application for import or export is really putting pressure on the operator to have done their due diligence before they actually seek that approval. So what does the due diligence statement contain? The regulation does provide some guidance, some of it's fairly basic, the operator's name and address, customs codes and quantity and quantities of the relevant commodity or product, the country of production, and the geolocation of all plots of land of production. And we'll talk a little bit about geolocation later.

As well as a general statement confirming that due diligence has been conducted and that negligible or low risk was concluded by the operator. The due diligence requirements of the regulation basically follow the basic steps for any company due diligence. So collection of information, risk assessment and risk mitigation. I will just over the next few slides make some points of note for each of these three different stages of the due diligence process. So the first step is to make sure that the company is in compliance with the relevant requirements. So starting with information requirements or access to information.

Operators are required to collect information, documents and other data demonstrating that the relevant commodities or products that they are importing or exporting are deforestation free and have been produced in accordance with the relevant legislation of the country of production. The steps, the step includes the collection of different types of information with the purpose of informing the risk assessment process. So we have some basic information requirements about the commodity or product itself, the country of production, a description of the product, the trade name or scientific name in the case of wood products, etc.

The operator is also required to obtain verifiable evidence that the product is deforestation free and or other evidence that the product has been produced in compliance with relevant legislation. However in article 9 there is one very important addition here. It's the one I've circled in red. For supply chains relevant to each product that's been placed on the market or exported, the operator must have the geolocation as well as the date or time range of production of the relevant commodities that were used within that product.

This applies to all supply chains whether or not from low or high risk countries and it is something that will be very much discussed in the coming months given the challenges that just exist for companies to obtain this type of information and have confidence in origin information. Geolocation is defined as the geographic location of a plot of land corresponding to at least one latitude and one longitude of the product. So the geolocation is defined as the geographic location one longitudinal point of that plot of land whether it be a forest or a farm.

For relevant commodities other than cattle and for plots of land that are greater than four hectares, geolocation means polygons, in other words sufficient latitude or longitudinal points to describe the perimeter of each plot of land. For cattle products the geolocation refers to these all of the different establishments where the cattle were raised or kept. So Article 10 requires the operators evaluate different types of risk. Risk that raw materials are not deforestation free, risks that they haven't been produced in accordance with the relevant legislation of the country of production, as well as risk of mixing i. e.

that products or commodities which are concluded as low risk may actually have been mixed in the supply chain with material of unknown origin or mixed with other materials which had a higher risk profile. Negligible risk as defined within the regulation basically just means that the full risk assessment for that product analyzing or evaluating both the product specific information but just general information on the area of production results in the operator having no cause for concern.

Operators also need to document the risk assessment process including just how information was gathered for the risk assessment, how it was checked against a set of risk assessment criteria which I'll just show you now, as well as how the operator determined the degree of risk. So the regulation provides a list of specific criteria that the risk assessment is required to take into consideration. The regulation provides a list of specific criteria that the operator has to take into consideration. So the operator needs to be able to determine the degree of risk assessment is required to take into consideration.

I'm not going to go into all the details because that list is quite long but some of these points are fairly logical considering the risks that are being evaluated. So obviously the presence of forests in the country of production would be an important risk consideration. The prevalence of deforestation or forest degradation in the area of production. Concerns in relation to the level of corruption, the prevalence of data falsification, the lack of law enforcement, armed conflict, the presence of sanctions imposed by the EU or United Nations. These are fairly straightforward in nature.

However, also drawing from some of the European Parliament amendments, the final additional, I should say, risk assessment criteria have been included in the final version of the regulation which strengthen the risk assessment in relation to international human rights and indigenous peoples. Including that the risk assessment cover the presence of the presence of the indigenous peoples in the country or the region of production, the existence of any claims or disputes by indigenous peoples regarding the use or ownership of the area, as well as the existence of any processes of consultation or cooperation with indigenous peoples within the area again of or the country of production. So the final assessment is the risk assessment criteria.

And the risk assessment is the risk assessment of the area of production. So the regulation is actually strengthening, if you like, the social dimension in comparison with the initial proposal. Deviating away from the requirements for due diligence, just for this slide, I just want to raise that a new development within the regulation is that the European Commission will develop and provide a central database of risk assessments or country benchmarks. The Commission will actually publish a three-tier list of low, standard, and high-risk countries for deforestation.

That list of countries or the list of countries which would be considered low or high risk will be published by the European Commission no later than 18 months after the entry into force of the regulation. However, until that point, all countries will effectively be assigned a standard risk. So why would the European Commission do this? The objectives, I think, are maybe among others. I can highlight two reasons for doing so. Firstly, the European Commission has sought to meet the proportionality principle of all EU laws where they try to minimize the burden of implementing the regulation, where it will have least impact in terms of the intended objectives.

Secondly, to really provide a top-level common agreement at the country level, at least for operators, as to which countries are broadly low or high risk. This is something that was maybe missing from the EU timber regulation and which would have been valuable to have, given that there was quite a significant variability in relation to, and there has been in relation to how different operators have viewed risks and the risk statuses or levels for particular countries or circumstances.

So the reason why I mentioned this is because, coming back to due diligence requirements, if operators are sourcing from countries that the Commission has designated as low risk, operators will be allowed to conduct what's called a simplified due diligence within the regulation, which includes only the first step of due diligence or the first stage, collecting information, documents, and data. The second step is to provide a standard risk collecting information, documents, and data, demonstrating that the products that they are importing or exporting are compliant with Article 3 of the regulation, that they're default-nation free and they've been legally produced.

So under these circumstances, sourcing from low risk countries, operators would be dispensed from carrying out those second and third stages of due diligence, in other words, the risk assessment and risk mitigation steps. Note, however, that the geolocation requirement still applies to an operator, even though the operator is implementing simplified due diligence. And the final step of the due diligence process is risk mitigation. Operators must have in place controls and procedures to mitigate and manage risks. The operator shall have adopted those risk mitigation measures where risks have been identified and prior to placing that product on the EU market or exporting it. On certification schemes, it's a risk mitigation measure.

Similarly to the EU timber regulation, the EU deforestation regulation recognises that certification or other third-party verified schemes can provide value in a risk assessment and risk mitigation process. However, there's no green lane for certification schemes. They should not sit on the EU timber regulation. There's no green lane for certification schemes. They should not substitute the operator's responsibility as regards due diligence. In other words, an operator cannot just automatically assume that without any further work, products which are certified would be somehow low risk. So I want to return to the information system described in articles 26 and 31 of the regulation.

This is an illustration of our kind of basic understanding of how the information system will work and be put into place, drawn from just the text of the regulation itself. Firstly, the commission raises that the information system will provide a series of functionalities. The registration of operators, the uploading and linking of due diligence statements with customs declarations. It will allow for the ability for competent authorities to record the outcomes of controls on due diligence statements and allow the risk profiling of operators and relevant commodities or products for the purposes of identifying high risk consignments.

If we just kind of work through this slide from the bottom left, the operator, the bottom left, will have to submit a due diligence statement with customs declarations to the information system, which has an interface linking with this EU single window environment for customs. When the operator applies for customs clearance, customs agents can then verify this application through the interface and link it with the due diligence statement that that same operator submitted. This slide of course is just focusing on the operator here.

There are some other aspects of this information system that we don't have time to cover, but I guess just to summarise, at least it's clear that there will be an online system where customs authorities can check due diligence information. And secondly, it's clear that competent authorities in their checks and inspections of operators will use it to verify which products an operator has imported or exported, as well as to ensure that the due diligence statements that were provided by those operators in their applications for customs clearance do provide correct and accurate information risk.

In terms of the quality management aspects of the due diligence system, the regulation describes that operators due diligence systems must be documented and that they be reviewed at least annually. For operators which are not SMEs, there are some additional requirements. The regulation describes the requirement for the appointment of a compliance officer at the management level, as well as that the operator implements an independent audit function to evaluate the effectiveness of the internal policies, controls and procedures that relate to the regulation. There is also for non-SMEs, micro-enterprises or natural persons, a public reporting requirement.

On an annual basis, operators must publicly report as widely as possible, including on the internet, that's straight from the regulation, on their due diligence system. If you are familiar with the FSC controlled wood system, you can imagine that the reporting requirements may be similar to some respects with the reporting requirements for FSC controlled wood, in that operators must describe which products are subject to the regulation, they must describe the risk conclusions that have been drawn in relation to those products imported or exported from the EU, as well as the risk mitigation measures that were taken to address those risks. So, the final part of this recording, controls and penalties.

So, very briefly, on controls and checks, again, it's the competent authorities that are responsible for implementation of the regulation and checks on operators. They'll use the information system, as I mentioned, to carry out a risk-based approach to selecting who or what is going to be evaluated or inspected. The next part of this recording is the control and penalties. So, the control and penalties are the ones that are expected. Competent authorities also have certain obligations to respond to substantiated concerns, such as where an NGO may submit a complaint against a company's activities, or raise concerns about non-compliances, or concerns about deforestation within the regulations.

The latest text of the regulation returns a little bit to the prescriptive nature, or the prescriptive wording, I should say, that was found in the original European Commission proposal on the regulation. The intensity of checks, basically, the regulation provides some guidance or instructions, if you like, on the intensity of checks which are required by competent authorities and operators. And that intensity of checks varies according to the risk status, if you like, of the commodities which have entered those products being imported or placed on the market or exported by the operator. So, to give an idea of range, operators which may be placing on the EU market or exporting products which are derived from high-risk commodities.

In that situation, the competent authorities are required to conduct checks of at least 9% of all operators using those high-risk commodities, as well as 9% of the quantity of each of the relevant products which would be considered high-risk. And then those percentages decrease according to standards and low-risk levels. And the final two slides, so there is provision for what the regulation calls corrective actions, and for competent authorities to require operators to take appropriate or proportionate corrective actions to rectify non-compliances. So, these may be literally any specific action that is required to take appropriate or proportionate corrective actions to rectify non-compliances.

So, these may be literally any specific action focused to rectify any formal non-compliance identified by the competent authority, preventing the relevant commodity or product from being placed on the EU market or exported, withdrawing or recalling the relevant commodity or product from the marketplace, donating the offending product to charitable or public interest purposes, as well as disposing of the product in line with EU rules on waste management. And then finally on penalties, member states, as I mentioned, are required to set penalty rates within certain limits. Those penalties shall be effective, proportionate to the size of the infractions, and generally dissuasive in nature, such that they determine compliance with the regulation and ensure that the regulation achieves its intended objectives.

And those types of penalties can be in the form of fines, confiscation of the relevant products concerned, confiscation of revenues gained by the operator as a result of trading or transactions with those offending products, exclusion, temporary exclusion from public procurement processes, up to 12 months, as well as a prohibition to trade or prohibition to the simplified due diligence procedure which is described within the regulation. That was my final slide, so I'd just like to say thank you very much. If you'd like to stay updated in relation to the EU deforestation regulation, as well as other activities being conducted under the LIFE project, please feel free to visit any one of these three websites. .

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New EU Deforestation Regulation – navigating the requirements

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