Committee on Import Licensing - Questions from Brazil to the European Union and to the EU 27 Member States

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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