Is the introduction of a zero-risk category a sensible way to ease the burden – or does it open the door to greenwashing and unfair competition?
3 Respuestas
Usuario anónimo
Hi Jada, thanks for raising this important and timely topic.
The idea of introducing a “zero-risk category” – as proposed by the German Bundesrat – aims to reduce administrative burden by exempting certain low-risk regions or products from full due diligence obligations under the EUDR.
Potential Benefits:
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Efficiency: Companies sourcing from well-governed, low-deforestation regions could focus resources on higher-risk supply chains.
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Proportionality: Risk-based approaches are standard in other EU regulations (e.g. CSDDD, LkSG), so applying this principle could increase acceptance and practicality.
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Relief for SMEs: Smaller players with limited compliance capacity could benefit disproportionately from such simplification.
But: Significant Concerns
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Greenwashing risk: A blanket exemption could lead to less scrutiny in regions where risks still exist (e.g. illegal logging in “low-risk” zones).
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Undermining EUDR credibility: If exceptions are too broad, the regulation risks losing effectiveness and public trust.
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Fair competition: Companies committed to full traceability might be disadvantaged compared to those sourcing from “exempt” regions.
Alternative approach: “Smart risk-based due diligence”
Rather than introducing a hard exemption, a tiered due diligence model (e.g. simplified DDS with reduced documentation for pre-verified low-risk areas) could strike a better balance — aligning with the EUDR’s objectives while addressing operational burdens.
Conclusion:
A “zero-risk” category might seem attractive at first glance, but it risks opening doors to abuse and inconsistent enforcement. A better path might be differentiated due diligence, not complete exemption.
Usuario anónimo
Hi Matthias, thanks for your response. I mean f.e. the wish from the German Budnesrat to introduce a “zero-risk category” to exclude low-risk regions from the EU Deforestation Regulation (EUDR). Kind regards, Jada
Usuario anónimo
Could you please explain what is meant by “Zero-Risk Category”? Do you mean the classification of the EU countries as “low risk”?
Best
Matthias