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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Hi everyone, and welcome back to Intertek’s Assurance in Action podcast!
My name is Yvonne Lenighan, and I’ll be your host for this episode. I lead the European office of our Assuris Food and Nutrition Group and we help companies comply with EU and UK regulations.
Today, I am sitting with my colleague Jayne Stewart, who will be telling us about the new European Deforestation Regulation.
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Thanks Yvonne, and hi everyone. Looking forward to having this discussion with you today!
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
So, let’s get started. Jayne, can you give us a brief overview of the new deforestation regulation and what this will mean for companies?
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Yes sure.
The new regulation is the European Union Deforestation Regulation – and this is often abbreviated as EUDR.
The aim of this regulation is to protect against deforestation and forest degradation globally, and the EU’s impact upon this.
This applies to the import and export of a number of commodities, to or from the EU.
There are 7 commodities listed within the regulation: cattle, cocoa, coffee, palm oil, rubber, soya, and wood, including any products derived from these commodities.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Wow, so that will impact a lot of companies – the food industry, to the tyre industry.
When will the regulation apply from?
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
The regulation is set to apply from December 30th, 2024.
Although it’s important to note that the regulation applies to commodities from land after the December 31st, 2020.
This may mean companies already have batches or stock that are produced from land after the year of 2020.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Ok, that is essential for many companies to know. In that case Jayne, what do companies need to do to comply with this regulation?
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Well, there are 3 key aspects companies will need to consider.
Firstly, companies should begin with a scoping phase – to determine which ingredients, products, or components fall within scope of the regulation. This will identify products, if any, that need to be brought forward to the risk assessment stage. At this stage, it’s also important to understand the end-to-end supply chain map for each product, which some refer to as the “chain of custody.” It’s important to ensure that all the product specifications are up-to-date and the countries of origin are an accurate reflection of the current supply chain.
Secondly, each company will need to build and maintain a risk assessment. There are 14 pillars noted within the regulation that need to be included in the risk assessment. Among those are the levels of forestry within each country, levels of corruption, and specific data relating to the supply chain of the product.
The third key aspect is the due diligence statement. This will need to be uploaded for both import and export of the commodities or products thereof, to provide evidence that the commodity is not taken from land that has been subject to deforestation after 31 December 2020. The statement includes a geolocation of all land plots used for growing the commodity, and will need to be uploaded on a batch-by-batch basis.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Ok, that is very clear, thank you. Is there a way for companies to determine which products are in scope if they are unsure?
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Yes, sure.
The regulation includes a list of products derived from the commodities we have mentioned. The products are organized with harmonized system codes, often referred to as HS codes. These codes are used for trading products globally.
A HS code consists of 6 digits, and it allows you to identify the product type.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Ah, interesting. Thank you for the detailed overview – there is a lot to take in!
So, I think for the benefit of our listeners – let’s put ourselves in a client/company’s shoes to better understand the requirement.
I will take on the role of the sustainability manager of a large bakery chain in Ireland. We make an array of products, and today we’re focused on, say, chocolate cupcakes as an example.
What aspects do I need to consider here to ensure our product is compliant? Cocoa is probably a good starting point here, I think!
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Yes, certainly the cocoa needs to be assessed. We need to first understand the supply chain for your purchased cocoa. Let’s assume it’s cocoa powder in this situation. We need to understand how you purchase the powder and who imports the powder to the EU. Once that’s determined, the initial due diligence upload will be completed by the importer of the product.
We then need to consider what countries your cocoa is grown in and the full details of your end-to-end map.
What do you think Yvonne, could you have any other ingredients potentially in scope?
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Ah, well yes we do use several different vegetable oils! I do think most of these oils are from sunflower sources though.
I would need to confirm this with our technical team.
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Well, sunflower would be out of scope. Maybe you have an emulsifier within the oil? This could potentially be derived from palm oil. It’s important to ensure you have this level of detail included on your specifications or product data sheets.
We would also need to assess all the ingredients within your product – there may be some other potential hidden ingredients derived from the commodities we spoke about.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Right! Wow, there are a lot of details to think about. I will have to check in with our teams regarding the accuracy and detail of our specifications.
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Sure.
So, how about the packaging of your cupcakes? We would need to consider these components also.
What type of packaging do the cupcakes use?
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Right, wood is also on the commodity list - I hadn’t even thought about the packaging! Our cupcakes all have a paper case, and then they are packaged in cardboard boxes with printed labels – which can be personalized for the costumer!
All of our packaging is FSC-certified though.
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Ah, unfortunately Yvonne, certifications like these do not mean compliance with the EUDR.
However, certificates are seen as complementary within the overall risk assessment.
This is still an advantage though – often the requirements for many of the certificate standards will mean you have a known end-to-end mapping and segregation in place along the supply chain.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Ah, that’s interesting, we will need to look into that here. There is certainly a lot to this regulation, and we have a pretty small technical team here. So, how can Intertek help me?
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Well, our regulatory experts would initially support with determining which products are in scope of the EUDR by reviewing the specifications and identifying which ingredients will need to be brought forward to the risk assessment stage. This will include identification of any potentially hidden components.
We can also support on the risk mitigation, supply chain mapping, and supplier training in countries of interest.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Ok, so, pretty comprehensive then! Thank you so much Jayne for the detailed overview. I’m sure it will be very beneficial for listeners trying to understand how to get help with EUDR compliance.
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Yes for sure, and we recommend that companies start preparing for the EUDR sooner rather than later. The regulation applies from the end of this year, and companies may already have batches that are produced from land after the year 2020.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Right – to our listeners, if you would like to know more about our EUDR services, please visit https://www.intertek.com/assuris/food/regulatory/eu-deforestation-regulation-eudr/
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Thanks, Yvonne, for being a wonderful host today and stepping into a client's shoes!
Also, I hope I can get some samples of your wonderful chocolate cupcakes.
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Speaker 1 – Yvonne Lenighan, Senior Manager, Food & Nutrition, Intertek Assuris
Oh absolutely, personalized to the EUDR!
It was a pleasure.
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Speaker 2 – Jayne Stewart, Dietary Intakes and Regulatory Manager
Yes, me too. Thanks again everyone for listening and have a wonderful day.
