G/AG/GEN/223  
 
15 September 2023  
(23-6142) Page: 1/4 
Committee on Agriculture  Original: English  
 
JOINT LETTER  
EUROPEAN UNION'S REGULATION ON DEFORESTATION -FREE PRODUCTS (EUDR)  
Submission by Indonesia, Brazil, and Malaysia  
The following submission, dated 14 September 2023, is being circulated at the request of the 
delegations of Indonesia, Brazil, and Malaysia . 
 
_______________  
 
 
This joint letter is being circulated to the Committee on Agriculture for transparency purposes only. 
  G/AG/GEN/223  
 
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  Brussels, 7 September  2023 
 
 
Honourable Roberta Metsola  
President of the European Parliament  
 
H.E. Charles Michel  
President of the European Council  
 
H.E. Ursula von der Leyen  
President of the European Commission  
 
H.E. Marcos Alonso Alonso  
Permanent Representative of Spain to the European Union  
Presidency of the Council of the European Union  
 
Dear Excellencies,  
 
We, the undersigned, wish to convey through this letter our de ep concern regarding the recent entry 
into force of the European Union's regulation on deforestation -free products (EUDR), on June 29, 
2023. As stated in the letter dated July 27, 2022 from a group of producing countries, this legislation 
disregards local circumstances and capabilities, national legislations and certification mechanisms of 
developing producer countries, their efforts to fight deforestation, and multilateral commitments, 
including the principle of common but differentiated responsibilities. It also establishes a unilateral 
benchmarking system that is inherently discriminatory and punitive, which is potentially inconsistent 
with WTO obligations.  
 
Considering that despite multiple manifestations of concern, particularly from developing countri es, 
the legislation will enter into application in less than 18 months, and that the EU is still working on 
its implementing acts and guidelines, we urge the Commission and other EU institutions to engage 
in a more meaningful and open dialogue with produci ng countries than what has been undertaken 
so far. The EU should work to repair this legislation, or, at a minimum, aim to mitigate its more 
harmful impacts through implementation guidelines that adequately value the current, as well as 
developing local su stainable practices in agricultural value chains, and avoid trade disruption 
including the excessive administrative burden related to the geolocation and traceability 
requirements, certifications, and customs procedures.  
 
The EU's "one -size-fits-all" appr oach, implemented through this model of due diligence and 
traceability, ignores the different local conditions and will inevitably impose immense costs on 
exporting and importing countries alike, as well as on producers and consumers. While these costs 
are certain, we consider that the legislation, by itself, will bear no positive impact on deforestation 
rates and may even produce other adverse effects, such as increased poverty, diversion of resources, 
and hindrance of the attainment of SDGs.  
 
Smallholders are especially vulnerable to the EUDR and require special support. The EU should 
acknowledge the efforts made by developing countries to improve their livelihood and sustainability 
practices as well as the significant challenges faced by them regarding limited access to financing 
schemes, new technologies and technical training and assistance.  
 
Smallholders may end up being excluded from international value chains not because they have 
deforested their land but due to their inability to show co mpliance with the stringent requirements 
imposed by the EUDR. That would unfairly deprive smallholders of an important source of income 
and livelihood, and even impact their ability to adopt sustainable practices. We call, therefore, on 
the Commission to f ormulate clear and detailed implementing acts and guidelines that include 
differentiated compliance and due diligence regimes for commodities and products originating from 
smallholders in developing countries, considering that EU SMEs will be granted more flexible 
treatment.  
 
In conclusion, we reiterate our commitment to the SDGs and to multilateral environmental 
agreements and goals. Given our shared objectives and the need to work together to tackle global 
challenges, we call on the EU to engage in effec tive cooperation and meaningful dialogue, with its 
partners in the areas of trade and sustainable development to jointly address the impact of EU 
legislation and its implementing instruments, including providing support to facilitate trade.  
 G/AG/GEN/223  
 
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  Please accept , Excellencies, the assurances of our highest consideration.  
 
Sincerely yours,  
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
  
G/AG/GEN/223  
 
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  CC: 
 
Honorable Heidi Hautala  
Vice President of the European Parliament  
 
Honorable Manfred Weber  
Chairman of the European People's Party Group  
 
Honorable lratxe Gar cía Pérez  
Chairman of the Progressive Alliance of Socialists and Democrats Group  
 
Honorable St éphane S éjourn é  
Presid ent of the Renew Europe Group  
 
Honourable Ska Keller and Philippe Lamberts  
Co-Presidents of Greens/European Free Alliance Group  
 
Honorable Marco Zanni  
President of Identity and Democracy Group  
 
Honorable Raffaele Fitto & Ryszard Antoni Legutko  
Co-Chairmen of the European Conservatives and Reformists Group  
 
Honourable Manon Aubry & Martin Schirdewan  
Co-President of the Left Group - GUE/NGL  
 
H.E. Mar oš Šefčovič  
Executive Vice -President for the European Green Deal  
 
H.E. Josep Borrell Fontelles  
High Representative of the European Union for Foreign Affairs  
and Security Policy  
 
H.E. Valdis Dombrovskis  
Commissioner for Trade and Executive Vice -President for an Economy that Works for People  
 
H.E. Janusz  Wojciechowski  
Commissioner for Agriculture  
 
H.E. Virginijus Sinkevi čius  
Commissioner for the Environment, Oceans and Fisheries  
 
H.E. Florika Fink -Hooijer  
Director General of ENVI  
 
H.E. Sabine Weyand  
Director General of TRADE  
 
H.E. Helena König  
Deputy Secretary General of the European External Action Service  
 
Honourable Pascal Canfin  
Chair of the Committee on the Environment, Public Health and Food Safety of the European 
Parliament  
 
Honourable Bernd Lange  
Chair of the Committee on International T rade of the European  
Parliament  
 
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