EUDR information system not yet on track to meet requirements of properly functioning supply chains

We, the undersigned organisations, call for:

1. Planning a second round of testing with the business community
The list of inaccuracies and errors reported to DG Environment at the outcome of the pilot testing was considerable. These issues, further to built-in limitations of the system, such as the 72-hour time window for amending
24ENV203  due diligence statements and the lack of automation, raised justified doubts within the business community that all problems will be resolved in one updated version. If these issues have indeed been solved, a second round of pilot testing and/or a continuous testing group should provide companies with much needed assurances. A dedicated stress test allowing companies to upload large amounts of geolocalisation data would also be needed.

2. Making the API specifications ready as of May for business to prepare
We welcome the fact that following industry feedback, an Application Programming Interface (API) is now being developed to ensure connectivity between our companies’ IT systems and the Information System itself. We would like to stress that our companies will need to significantly revamp their IT systems to connect with the API – a process that takes few months and can only be achieved if the API specifications provide precise information regarding purpose, type, endpoints, HTTP methods, data formats, parameters, authentication and security of the API.

3. Lifting the 25MB limitation or substantially increasing file size for uploading files as part of the due diligence statement
For bulk commodities and liquids, but also for derived products, the envisaged 25MB data limit, which represents about 1 million data points, is insufficient as this number is likely to be reached within few weeks of cumulated geolocation data from polygons. Several of our commodities are cumulatively sourced from hundreds of thousands of smallholder farmers. In addition, polygons are the preferred method to indicate the area of production of goods, due to their higher accuracy compared to single geolocation points. Combining the large number of suppliers with the large amount of data points contained within each polygon, it is easy to reach the threshold of one million data points contained in a 25MB file within a couple of cumulated shipments.

4. Accepting other data formats than the only GeoJson standard
Pre-existing work on traceability has been built using different data formats. Less than 8 months before application, limiting transferable format standards to one (GeoJson) disregards the extensive work that has been done and rolls over the burden to operators instead of providing workable IT solutions. The ability to use additional data formats, which as industry representatives we were asked to provide in June 2023, should be allowed.

5. Opening up the information system for all users as soon as possible and, at the very latest, beginning of November
The current timeline to make the Information System available for general use as of mid-December only, is totally underestimating the reality of supply chains, as most harvests, from Autumn onwards, may only arrive in the European Union after the date of application and would then require an accompanying due diligence statement. A time period of merely two weeks is insufficient for companies to create all these statements. In addition, hands-on time is needed for all handlers, outside of training context to familiarise themselves with this new environment, ensure connection with their own data management system and train appropriately relevant staff.