The EUDR (EU Deforestation Regulation) requires the disclosure of geolocation data on the origin of raw materials when importing into the EU. A crucial prerequisite for this is supply chain traceability. This means that for every imported raw material, it must be proven where it comes from – and that the respective origin is not affected by deforestation.
In many regions, raw materials come from smallholder farms, particularly in furniture production based on agricultural by-products such as mango wood. Local conditions that may be unfamiliar in the EU play a major role here: mango trees in India grow mainly on small plantations and private land. Acacia, sheesham or teak also frequently comes from such cultivation areas.
What approaches can be derived from this situation, particularly with regard to the entry into force of the EUDR on 30 December 2024?
The regulation highlights risk-mitigating measures, including 'supporting compliance with this regulation by their suppliers, in particular smallholders, through training and investment aimed at improving smallholders' access to relevant information on the compliance requirements and procedures of this regulation' (EUDR, Art. 10 (2)(p)).
Recognising the role of smallholders
The regulation explicitly emphasises the recognition and empowerment of the role and rights of smallholders and micro-enterprises in producer countries. It also mentions partnership programmes designed to expand smallholder opportunities and provide practical benefit through improved infrastructure and technology.
For now, however, these remain 'fine words', because by the time corresponding programmes are planned and implemented, smallholders will likely have long since disappeared from supply chains – because they represent a high risk under the EUDR if such origins cannot be traced back to the plot level.
Adding to the difficulty is the fact that in India, such timber is typically sold on local markets where nobody cares about its origin. Accordingly, no (geo-)data is passed on either.
From a 'risk logic' perspective, deforestation risk can be excluded for timber originating from agricultural structures – the land is already deforested. As with the EUTR (EU Timber Regulation) before it, it is very unfortunate that the regulation does not provide for a risk assessment based solely on the species of wood. This would help smallholders in the supply chains for mango, sheesham, acacia and rubber wood far more than any potential EU programmes.
The role of supplycanvas and outlook
Software such as supplycanvas offers a simple and free solution for suppliers, though the disclosure of geolocation data requires a fundamental shift in local business practices. supplycanvas is committed to facilitating this change by providing both importers and exporters with practical, technology-driven tools. However, a comprehensive transition and the sharing of origin information along the entire supply chain will require at least sustained long-term effort.
Urgency of partnership programmes
Particularly for the timber species mentioned, the partnership programmes outlined in the regulation – regardless of their specific design – are undeniably critical and must be advanced urgently. Workshops and training alone will not be sufficient.