What does it take to implement the proposed rules? A member state view
EJD's DG Geneviève Pons talked about what EJD has identified as the weak and strong points of the proposed deforestation regulation. Starting with the strengths, the inclusion of due-diligence obligations addressing deforestation in the EU and abroad is surely a bright spot of the regulation. Moreover, she welcomed the fact that the proposed regulation addresses both legal and illegal deforestation and the commodity-based approach followed by this legislation. In particular, this approach will ensure that the regulation will comply with international and WTO law.
She did not shy away from listing the weaknesses of the proposed regulation. The main weak points of the proposed text concern the risks of leakage effects and loopholes linked to the implementation of a non-universal commodity-based approach and the opt-out conceded to the financial sector.
Geneviève Pons addressed then the challenges that the regulation will face in the implementation phase. Three issues stand out as the most pressing ones: the companies' degree of implementation of the due-diligence system; the benchmarking and traceability issues and the establishment of control systems through national authorities.
She concluded her intervention by tracing 3 possible paths of intervention: ensuring a robust and enforceable regulatory framework, providing complementary measures and ensuring consistency with other related legislative instruments.