ACEA对欧盟森林砍伐法规的立场

ACEApositionon the EUDeforestation Regulation GENERAL CONTEXT European vehicle manufacturers have a long-held and firm commitment to sustainability.There is an understanding for the ambition of the EU to minimise the European contributionto global deforestation and forest degradation, to counteract the loss of biodiversity andclimate change. To this end, the Deforestation Regulation (EUDR)lays down rulesregarding the placing and making available on the Union market as well as the export fromthe Union of relevant products. The automotive industry has one of the mostcomplex supply chainswith multiple layers ofparts suppliers. This remains challenging when it comes to mapping out of the OEMs’ supplychains, carrying out risk assessments, and risk mitigation (includingending collaborationsand finding new suppliers if mitigation is impossible). Increased complexity that comes with the implementation of the EUDRplaces increasedburdens on companies,egthrough investments that are needed to comply withimplementation, setting up technical support and so on. This all comes with an impact on theOEMs’competitiveness. The EUDR remains a very complex regulation, despite the Commission’s efforts forclarifications through the published FAQs in December 2024 and April 2025, as well as theApril 2025 draft Delegated Act. From our point of view, it remains imperative for the Commission to further simplify theEUDR before it is put into effect and to clarify open questions. An extension of the scope,ascurrently foreseen in the reviewprocess,is therefore not advisable at this time. KEY CONCERNS In order to prepare for the implementation of the regulation on30December2025, ourmembers continue to face numerous practical questions. Besides the published and updatedFAQs and guidance document (https://green-business.ec.europa.eu/deforestation-regulation-implementation_en),there are still many issues to be clarified. Below,the most criticalaspects in need for clarification/amendments are presented: •Introduction of a minimum threshold.The EUDR lacks minimum thresholds forrelevant products. This results in unproportional efforts for the setting up of duediligence and risk management processes. If a relevant product contains less than acertain percentage of the EUDR commodity in question, this product should beexempted from the EUDR. The same should apply for products which are below acertain weight threshold of the commodity contained (egxxgrams).Alternatively,deliveries of EUDR relevant products with a value below€1,000should not beincluded in the EUDR’s scope. •Limit focus on the first placing on the EU market;avoidance of intra-EUtracing.Significant relief for all affected companies can be achieved if the EUDR due diligence obligations were to applyonly to the first placing on the EU market ofthe relevant raw materials and products.Aneffective, but simplified approach canbe taken, while maintaining the spirit of the EUDR to secure an efficient control ofpreventing uncompliant material/parts to enter the EUby: •Avoidance of intra-EU tracing.Limitation of the traceability obligation to the firstplacing on the EU market to avoid repeating due diligence obligations anduselessadditional burdens and repeated obligations on the various actors’downstream supply chain. •General exemption of intra-group activities.The currently planned reneweddue diligence obligations include transfers within a corporate group.As theseintra-group activities only have a limited impact on EUDR, but come with anincreased bureaucratic burden, group trading activities should be exempted fromany obligations. •Keep focus on New Type mass production and exempt already on the marketspare parts.It must be ensured that placing on the market of spare parts forvehicles,which are no longer in production,does not trigger due diligenceobligations. Spare parts are long-lasting consumer products and the EUDR shouldtake into account the fact that they enable longer use of the product, in this case thevehicle, which is beneficial. Additionally, uncertaintyexists due to unclarity whichdata suppliers will have to pass on to next recipients in the supply chain,egwhenparts are placed on the market 10 years after they were purchased by the supplier,given the fact that currently the retention period for EUDR data is five years. Giventhese concerns, we recommend focus to be kept solely onspare parts, destined tovehicleswhich are currently being produced (ocus on“new type”mass productionparts). •Imports-only scope.In particular, there should be equal treatment oftraders andSMEs, so that they do not have to fulfill due diligence obligations if these havealready been fulfilled once for the products(see for SMEs Art. 4 (8) EUDR). Againstthis background, and in the view of simplification, the European Commission couldconsider reducing the scope of EUDR to imports only. •Risk-based approach.Currently the EUDR provides for a success obligation tooperators/traders to conduct due d