QUESTIONS FROM BRAZIL TO THE EUROPEAN UNION
AND TO THE EU 27 MEMBER STATES
The following communication,
dated 25 September 2025, is being circulated at the request of the delegation
of Brazil.
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1._
Brazil notes that
the "European Union Deforestation Regulation" (EUDR), adopted as
Regulation (EU) 2023/1115 of the European Parliament and of The Council,
creates the obligation that operators should submit a due diligence statement
prior to the placement into EU's market of the products covered by that
regulation. In that regard, Brazil makes the following questions:
a._
Is the submission
of the due diligence statement considered a prior condition for the importation
into the customs territory of the EU, as defined in Art. 1:1 of the WTO
Agreement on Import Licensing Procedures?
b._
Is it possible
that each EU Member State adopts different requirements in their respective due
diligence form?
2._
Brazil also takes
the opportunity to seek clarifications from all EU member States on the
implementation of the EUDR at their national level and thereby consults on the
following:
a._
Do you envisage
adopting different or additional requirements in your national due diligence
form?
b._
When do you
envisage making the notification of the corresponding import licensing
administrative procedures required for the implementation of the EUDR at the
national level?
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