Response to the European Commissiond Interim Findings on the Fitness Check of Illegal Logging Rules

ClientEarth argues that the European Commission's interim findings on illegal logging rules fail to adequately account for the positive systemic impacts of the EUTR and FLEGT Regulation while overlooking critical enforcement gaps. The organization recommends harmonizing obligations across the supply chain, creating a centralized public registry for compliance data, and adopting a legal definition of 'substantiated concerns' to aid prosecutors. Regarding FLEGT, ClientEarth contends that the slow pace of licensing is a result of the necessary complexity of legal reforms in partner countries and warns that weak EUTR enforcement reduces the incentive for third countries to engage in VPA processes.

• The European Commission's interim findings are criticized for lacking information on the positive results of the EUTR and FLEGT Regulation and for failing to propose options to address identified concerns.
• ClientEarth identifies a critical causal link where inadequate implementation and enforcement of the EUTR discourages third countries from establishing FLEGT-VPA licensing schemes, as the incentive for market access is eroded.
• To improve EUTR enforcement, ClientEarth recommends harmonizing obligations so that traders face requirements equivalent to those of operators, preventing the trader's role from being used to evade compliance.
• The document proposes several technical and legal improvements for the EUTR, including the creation of a centralized public registry for compliance checks and the adoption of a formal legal definition for 'substantiated concerns' to assist prosecutors.
• ClientEarth argues that the high costs of compliance cited by some are not a flaw of the EUTR itself, but rather a result of operators choosing complex supply chains over more transparent ones.
• Regarding FLEGT, ClientEarth asserts that the regulation's success should be measured by systemic changes in forest governance and the recognition of local community and indigenous peoples' (LCIPs) rights, rather than solely by monetized benefits.

APA

ClientEarth (2021). Response to the European Commissiond Interim Findings on the Fitness Check of Illegal Logging Rules. https://www.clientearth.org/media/u1hnadqx/clientearth_response-to-the-commission-s-interim-findings-on-the-fitness-check-of-illegal-logging-rules.pdf

Chicago

ClientEarth. Response to the European Commissiond Interim Findings on the Fitness Check of Illegal Logging Rules. 2021. https://www.clientearth.org/media/u1hnadqx/clientearth_response-to-the-commission-s-interim-findings-on-the-fitness-check-of-illegal-logging-rules.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Response to the European Commissiond Interim Findings on the Fitness Check of Illegal Logging Rules |date=April 2021 |url=https://www.clientearth.org/media/u1hnadqx/clientearth_response-to-the-commission-s-interim-findings-on-the-fitness-check-of-illegal-logging-rules.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021response, author = {{ClientEarth}}, title = {{Response to the European Commissiond Interim Findings on the Fitness Check of Illegal Logging Rules}}, publisher = {ClientEarth}, year = {2021}, month = apr, url = {https://www.clientearth.org/media/u1hnadqx/clientearth_response-to-the-commission-s-interim-findings-on-the-fitness-check-of-illegal-logging-rules.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }