JBCE submitted the position paper on the product scope of the EUDR

04/06/2026

On 1 June 2026, The Japan Business Council in Europe (JBCE) submitted its views on the product scope of the EU Deforestation Regulation (EUDR), in the context of the draft delegated act revising Annex I of the Regulation.

 

JBCE supports an effective and proportionate implementation of the EUDR and acknowledges the simplification efforts already made by the European Commission, such as the exemption of downstream operators and the exclusion of certain paper products. To further improve legal certainty, feasibility and proportionality across supply chains, JBCE calls for two main adjustments.

• Exempting additional products whose inclusion would create disproportionate compliance burdens with a negligible contribution to preventing deforestation: rubber parts containing negligible amounts of natural rubber (with exemptions based on the volume and weight of natural rubber per item); spare parts of products already placed on the EU market, including legacy service parts for vehicles and machinery that remain in operation for decades; empty replacement packaging materials imported solely to replace damaged original packaging; and separately imported information materials, such as labels, affixed during localisation after import.
• Accepting alternative information, namely the country of harvest and sub-national region, and giving due consideration to established certifications such as PEFC and FSC, where precise geolocation data cannot be obtained, in particular for paper products with highly complex, multi-source supply chains.

 

JBCE calls on the European Commission to make compliance with the EUDR more feasible in practice for economic operators by introducing the aforementioned adjustments to the scope and the implementation.

 

Asuka Yui, Kaori Tamamushi

Policy Manager

Corporate Sustainability, Trade Policy

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Download documents: JBCE Position Paper on the Targeted Exemptions and Clarifications of Product Scope under the EUDR