EUDR - information from SCA

Implementation status

On December 3rd, EU Parliament, the Council and the Commission voted on a prolonged implementation time of 12 months which was approved. The proposed changes were not accepted meaning that the amendments, including the proposal for a new risk category “no risk” will not be implemented. Instead, an agreement was made that the Commission should investigate how to simplify the regulation and reduce regulatory burden, especially for smaller companies, when the legislation is reviewed in 2028.

This new proposal will need to be voted on at the Parliament’s plenary on the week of Dec. 16 before it can be published in the EU Official Journal and enter into force three days later.

The risk-classification of countries should be finished by December 30^th, 2024. Following the methodology applied, a large majority of countries worldwide will be classified as ‘low risk' according to the commission. But if the proposed changes come into force the Commission will have to finalise the country benchmarking system by 30 June 2025.

The work is still ongoing to evaluate the regulatory steps needed to adopt Swedish legislation according to EUDR. The competent authority in Sweden, the Swedish Forest Agency (Skogsstyrelsen), have started open sessions for the public to ask questions about the implementation of the regulation.

There are still some uncertainties on how traceability and due diligence shall be performed, which will be further clarified in the EU Commission work group on the issue. A guidance document and the third version of the FAQ was published on October 2^nd, but questions still remain.

Ongoing activities

At SCA we are working actively with the implementation regardless of the proposed postponement. We are in dialogue with the EU and Swedish authorities as well as customers, the forest industry and certification organisations.

In Sweden, the forest industry has a common platform to oversee the traceability of wood but the EUDR’s requirements will extend beyond its current capabilities. To solve this, we are working to develop the systems needed to comply when EUDR comes into force. A Swedish common model (for tree-based products), based on reporting in excess, was presented in August.

The Swedish company Biometria (responsible for the measuring of the timber) have decided to provide support in the VIOL-system, enabling the transactions of reference numbers. All parties involved in the raw material affair will then have the information that a declaration has been made together with the reference number(s) connected to the delivery.

A test pilot phase of the EUDR Information system took place between December 18, 2023 and January 31, 2024. An API (Application Programming Interface) which can communicate with the information system has been developed as an outcome of the test pilot. The system opened for operators to register on November 6^th. Now the system has opened for submission of due diligence statements, both in a live and acceptance (test) version. Both the LIVE Server and ACCEPTANCE Server are available in all EU languages.

Expectations going forward

There are still a lot of issues to be solved. We have, together with the Swedish Forest Industries Federation, identified some overall questions that needs to be answered:

• How can we secure traceability through industry and logistic facilities?
  Work is ongoing to have robust practically implementable solutions.

• Which information should be forwarded to customers in addition to reference numbers?
  Information about geolocations can be hidden in the EU information system, suggesting that this data does not have to be shared. Other information, for example about legality, needs to be decided on when to share.

• How can responsibility and sanctions be delimited to the actor in the supply chain that violated the regulation and to the actual volume of raw material or product that is illicit? 
  This must be clarified by the commission, but also interpreted by the Swedish competent authority.

• Will Sweden be classified as a low-risk country?
  According to the commission, following the methodology applied, a large majority of countries worldwide will be classified as ‘low risk'. 

• How will the assessment criteria for forest destruction come out and what sanctions will apply in Sweden?
  Ongoing investigation at a national level. 

• What constitutes relevant legislation in Sweden and what documentation is required?
  Ongoing investigation at a national level.

Implementation status

The work is still ongoing to evaluate the regulatory steps needed to adopt Swedish legislation according to EUDR. The competent authority in Sweden, the Swedish Forest Agency (Skogsstyrelsen), have started open sessions for the public to ask questions about the implementation of the regulation.

There are still some uncertainties on how traceability and due diligence shall be performed, which will be further clarified in the EU Commission work group on the issue. A guidance document and the third version of the FAQ was published on October 2^nd, but questions still remain.

The risk-classification of countries should be finished by December 30^th, 2024. Following the methodology applied, a large majority of countries worldwide will be classified as ‘low risk' according to the commission.

Ongoing activities

At SCA we are working actively with the implementation regardless of the proposed postponement. We are in dialogue with the EU and Swedish authorities as well as customers, the forest industry and certification organisations.

In Sweden, the forest industry has a common platform to oversee the traceability of wood but the EUDR’s requirements will extend beyond its current capabilities. To solve this, we are working to develop the systems needed to comply by the end of 2024. A Swedish common model (for tree-based products), based on reporting in excess, was presented in August.

The Swedish company Biometria (responsible for the measuring of the timber) have decided to provide support in the VIOL-system, enabling the transactions of reference numbers. All parties involved in the raw material affair will then have the information that a declaration has been made together with the reference number(s) connected to the delivery.

A test pilot phase of the EUDR Information system took place between December 18, 2023 and January 31, 2024. An API (Application Programming Interface) which can communicate with the information system has been developed as an outcome of the test pilot. Updates due to the pilot testing are still on-going. The system will open for registration at the beginning of November and open to full extent on December 2nd.

Expectations going forward

There are still a lot of issues to be solved. We have, together with the Swedish Forest Industries Federation, identified some overall questions that needs to be answered:

• How can we secure traceability through industry and logistic facilities? 
  Work is ongoing to have robust practically implementable solutions.

• Which information should be forwarded to customers in addition to reference numbers? 
  Information about geolocations can be hidden in the EU information system, suggesting that this data does not have to be shared. Other information, for example about legality, needs to be decided on when to share.

• How can responsibility and sanctions be delimited to the actor in the supply chain that violated the regulation and to the actual volume of raw material or product that is illicit? 
  This must be clarified by the commission, but also interpreted by the Swedish competent authority.

• Will Sweden be classified as a low-risk country? 
  According to the commission, following the methodology applied, a large majority of countries worldwide will be classified as ‘low risk'. 

• How will the assessment criteria for forest destruction come out and what sanctions will apply in Sweden? 
  Ongoing investigation at a national level. 

• What constitutes relevant legislation in Sweden and what documentation is required? 
  Ongoing investigation at a national level.

Implementation status

The Swedish government has appointed a committee to evaluate the regulatory steps needed. The competent authority in Sweden has been appointed and the mission for supervision is assigned the Swedish Forest Agency (Skogsstyrelsen).

There are still some uncertainties on how traceability and due diligence shall be performed, which will be further clarified in the EU Commission work group on the issue. Further aspects regarding risk-classification of countries will be clarified in the Member States implementation processes. 

Ongoing activities

We are in dialogue with the EU and Swedish authorities as well as customers, the forest industry and certification organisations.

In Sweden, the forest industry has a common platform to oversee the traceability of wood but the EUDR’s requirements will extend beyond its current capabilities. To solve this, we are actively working to develop the systems needed to comply by the end of 2024. A Swedish common model (for tree-based products) will be presented in August.

The Swedish company Biometria (responsible for the measuring of the timber) have decided to provide support in the VIOL-system, enabling the transactions of reference numbers. All parties involved in the raw material affair will then have the information that a declaration has been done and the reference number(s) connected to the delivery.
A test pilot phase of the EUDR Information system took place between December 18, 2023 and January 31, 2024.

An API (Application Programming Interface) which can communicate with the information system has been developed as an outcome of the test pilot. Updates due to the pilot testing is still on-going and the system will open on December 2nd.

Expectations going forward

There all still a lot of issues to be solved. We have, together with the Swedish Forest Industries Federation, identified two overall questions that needs to be answered by the EU commission, and that we are actively working on as well:

• Is there a possibility to use mass balance for the traceability through terminals and industries?
• What are the criteria to fulfill due diligence and the documentation coupled to that?

We also wait for promised guidelines and new FAQ from the EU.

Implementation status

The Swedish government has appointed a committee to evaluate the regulatory steps needed. The competent authority in Sweden has been appointed and the mission for supervision is assigned the Swedish Forest Agency (Skogsstyrelsen).

There are still some uncertainties on how traceability and due diligence shall be performed, which will be further clarified in the EU Commission work group on the issue. Further aspects regarding risk-classification of countries will be clarified in the Member States implementation processes. 

Ongoing activities

We are in dialogue with the EU and Swedish authorities as well as customers, the forest industry and certification organisations.

In Sweden, the forest industry has a common platform to oversee the traceability of wood but the EUDR’s requirements will extend beyond its current capabilities. To solve this, we are actively working to develop the systems needed to comply by the end of 2024.

A test pilot phase of the EUDR Information system took place between December18, 2023 and  January 31, 2024. One of the outcomes was that there is a need of an API (Application Programming Interface). Development due to the pilot testing is still on-going.

The Swedish company Biometria (responsible for the measuring of the timber) have decided to provide support in the VIOL-system, enabling the transactions of reference numbers. All parties involved in the raw material affair will then have the information that a declaration has been done and the reference number(s) connected to the delivery.

Expectations going forward

There all still a lot of issues to be solved. We have, together with the Swedish Forest Industries Federation, identified two overall questions that needs to be answered by the EU commission, and that we are actively working on as well:

• Is there a possibility to use mass balance for the traceability through terminals and industries?
• What are the criteria to fulfill due diligence and the documentation coupled to that?

We also wait for promised guidelines and new FAQ from the EU.

Implementation status

The Swedish government has appointed a committee to evaluate the regulatory steps needed.The competent authority in Sweden has been appointed and the mission for supervision is assigned the Swedish Forest Agency (Skogsstyrelsen).

There are still uncertainties on how traceability and due diligence shall be performed, which will be further clarified in the EU Commission work group on the issue. Further aspects regarding risk-classification of countries will be clarified in the Member States implementation processes. 

Ongoing activities

We are in dialogue with the EU and Swedish authorities as well as customers, the forest industry and certification organisations.

In Sweden, the forest industry has a common platform to oversee the traceability of wood but the EUDR’s requirements will extend beyond its current capabilities. To solve this, we are actively working  to develop the systems needed to comply by the end of 2024.
At the moment we are evaluating the EUDR Information system during the ongoing test pilot phase, 18 th December 2023 to 31 January 2024

Expectations going forward

• We are looking forward to taking part of the results from the Information system test pilot.
• Meetings will be set up with the Swedish Forest Agency (competent authority).
• Our close co-operation with the forest industry in Sweden and Europe will continue.

Implementation status

On November 14th, EU Parliament voted on a prolonged implementation time of 12 months which was approved. They also adopted other amendments proposed by the political groups, including the creation of a new risk category of countries, “no risk”. Countries classified as “no risk”, would face significantly less stringent requirements as there is a negligible or non-existent risk of deforestation. Parliament decided to refer this file back to committee for interinstitutional negotiations. For these changes to enter into force, the agreed text will have to be endorsed by both Council and Parliament and published in the EU Official Journal.

The risk-classification of countries should be finished by December 30^th, 2024. Following the methodology applied, a large majority of countries worldwide will be classified as ‘low risk' according to the commission. But if the proposed changes come into force the Commission will have to finalise the country benchmarking system by 30 June 2025.

The work is still ongoing to evaluate the regulatory steps needed to adopt Swedish legislation according to EUDR. The competent authority in Sweden, the Swedish Forest Agency (Skogsstyrelsen), have started open sessions for the public to ask questions about the implementation of the regulation.

There are still some uncertainties on how traceability and due diligence shall be performed, which will be further clarified in the EU Commission work group on the issue. A guidance document and the third version of the FAQ was published on October 2^nd, but questions still remain.

Ongoing activities

At SCA we are working actively with the implementation regardless of the proposed postponement. We are in dialogue with the EU and Swedish authorities as well as customers, the forest industry and certification organisations.

In Sweden, the forest industry has a common platform to oversee the traceability of wood but the EUDR’s requirements will extend beyond its current capabilities. To solve this, we are working to develop the systems needed to comply by the end of 2024. A Swedish common model (for tree-based products), based on reporting in excess, was presented in August.

The Swedish company Biometria (responsible for the measuring of the timber) have decided to provide support in the VIOL-system, enabling the transactions of reference numbers. All parties involved in the raw material affair will then have the information that a declaration has been made together with the reference number(s) connected to the delivery.

A test pilot phase of the EUDR Information system took place between December 18, 2023 and January 31, 2024. An API (Application Programming Interface) which can communicate with the information system has been developed as an outcome of the test pilot. Updates due to the pilot testing are still on-going. The system opened for operators to register on November 6^th. Earlier it was announced that the system would open to full extent on December 2^nd, but this has now been changed to that the system will be opened for submission of due diligence statements ahead of the entry into application.

Expectations going forward

There are still a lot of issues to be solved. We have, together with the Swedish Forest Industries Federation, identified some overall questions that needs to be answered:

• How can we secure traceability through industry and logistic facilities?
  Work is ongoing to have robust practically implementable solutions.

• Which information should be forwarded to customers in addition to reference numbers?
  Information about geolocations can be hidden in the EU information system, suggesting that this data does not have to be shared. Other information, for example about legality, needs to be decided on when to share.

• How can responsibility and sanctions be delimited to the actor in the supply chain that violated the regulation and to the actual volume of raw material or product that is illicit? 
  This must be clarified by the commission, but also interpreted by the Swedish competent authority.

• Will Sweden be classified as a low-risk country?
  According to the commission, following the methodology applied, a large majority of countries worldwide will be classified as ‘low risk'. 

• How will the assessment criteria for forest destruction come out and what sanctions will apply in Sweden?
  Ongoing investigation at a national level. 

• What constitutes relevant legislation in Sweden and what documentation is required?
  Ongoing investigation at a national level.