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          starts being enforced, it "could have significant negative   met for smooth implementation of the law” while keeping the
          economic effects on both producers and consumers on both   situation “under constant review”.
          sides of the Atlantic", the letter said according to Argus Media.
            "We therefore urge the EU Commission to delay the   Mounting calls for EUDR delay from inside the EU

          implementation of this regulation and subsequent enforcement   Calls for a delay to implementation EUDR have become louder
          of penalties" until the challenges have been addressed, it   inside the EU itself in recent months.
          added.                                                The first signs of internal dissent came on 12 March in a
            The letter follows on from an earlier letter sent to US trade   letter sent to the EC signed by six European wood industry
          representative Tai by 66 members of Congress in October   organisations (CEI-Bois, EFIC, EOS, EPF, ETTF, and FEP).
          last year. This letter requested that the trade representative   This was followed on 13 March by a similar letter signed
          raised the challenges that US paper and pulp producers   by 19 wood trade organisations in France sent to the French
          were facing due to the EU’s deforestation law with Brussels.   Environment Minister.
            “The EU’s regulation imposes impractical requirements that   The calls for delay escalated in a meeting of the European

          would unnecessarily restrict trade for products from low-risk   Agriculture and Fisheries Council on 26 March when Agriculture
          countries that have responsibly managed supply chains, such   ministers from 20 of the EU's 27 member countries supported
          as the US,” the congressional the letter said.     a proposal by Austria to revise the law. The FT reports
            The Financial Times (FT), in an article published 17 June   that EU’s development commissioner Jutta Urpilainen and
          confirming that the US government had sent a letter to the   agriculture  commissioner  Janusz  Wojciechowski  have also
          EC, noted that the EU imported about US$3.5 billion of   both called for a delay EUDR in recent months.
          American forest-based products in 2022.               On 17 May, the German Bundesrat passed a motion

            This included around US$2.2 billion of pulp and paper,   on the EUDR “calling for an extended implementation and
          US$0.7 billion of pellets, and US$0.6 billion of other wood   to relieve producers of avoidable, additional bureaucracy
          products. The FT noted that “US timber merchants have said   where there is no demonstrable risk". The Bundesrat is the
          they are considering cutting EU export contracts because they   upper chamber of the German government where the Länder
          cannot prove their paper does not come from deforested land”.   (States) are represented.
            A spokesperson for the American Forest and Paper    The Bundesrat motion is explicit in its critique of the law
          Association (AF&PA) told the FT that it was “impossible” for   noting that “in view of the tight implementation period until
          U.S. pulp and paper products to comply with the geolocation
          requirements of the EUDR because these are made principally

          from leftover sawmill and forest residue blended from different                                     rawpixel.com
          sources.
            “This makes tracing each individual wood chip back to the
          original forest plot of land effectively impossible. Additionally,
          the technology needed to trace our fibre flow to comply with
          this requirement does not currently exist,” AF&PA told the FT.
            Euronews reported that, in responding to questions about

          the EU’s reaction to the US letter, an EC spokesperson said
          they had been “working hard to ensure all the conditions are
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