ACEA position on the EU Deforestation Regulation

The Deforestation Regulation (EUDR) implementation places increased burdens on companies, jeopardising European vehicle manufacturers’ competitiveness at a critical moment our industry faces unprecedented challenges.

Before the European Commission puts its regulation into effect, ACEA advocates for further simplification of the EUDR and the need for clarifications and amendments:

1. Introduction of a minimum threshold
2. Limiting focus on the first placing on the EU market; avoidance of intra-EU tracing
3. Keeping focus on New Type mass production; exemption for spare parts already on the market
4. Imports-only scope, to avoid due diligence obligations being fulfilled twice
5. A risk-based approach should be introduced to focus on deforestation risks and streamline due diligence, allowing companies to conduct targeted risk analysis and better implement the regulation
6. Establishment of a more reliable geolocation system
7. The EUDR’s requirement for ‘adequately conclusive and verifiable information’ is unclear, making it difficult for companies to comply without investing significant resources to interpret these uncertainties
8. More focused approach on the number of products rather than their weight
9. General exemption for test materials, prototype parts, and pre-production parts

The European Automobile Manufacturers’ Association (ACEA) is fully committed to sustainability and supports the EU ambition to minimise its contribution to global deforestation. However, the automotive industry has one of the most complex supply chains, with multiple layers of parts suppliers.