Ensuring EUDR benchmarking reflects human rights and environmental risks
28 January 2025

The European Commission must ensure that benchmarking under the European Union Regulation on Deforestation-free Products (EUDR) upholds the law’s ambitions and reflects human rights and deforestation risks existing in areas of production.
This joint letter from 40 organisations calls on the Commission to ensure that the benchmarking methodology:
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Considers human rights violations and risks of illegality from the outset for all countries, consistently with Article 29(4)(c) and (d), including for countries with low deforestation or forest degradation rates;
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Does not use UN sanctions as sole criteria to determine whether a country or parts thereof are high risk;
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Considers forest degradation alongside deforestation, which is consistent with the text of the regulation;
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Considers production trends for all commodities covered by the EUDR;
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Does not unduly characterise trade agreements as neutralising measurable risks of deforestation, illegality, and rights violations.
Categories: NGO Statements, EU Regulation on deforestation-free products