Early this month, the European Commission (EC) recommended a 12-month delay for the EU Deforestation Regulation (EUDR). If approved by the European Parliament and the Council, it would make the law applicable on December 30, 2025, for large companies and June 30, 2026, for micro and small enterprises.
The EC also released a guidance document to support global stakeholders, EU member states and third countries in their preparations for the EUDR’s implementation. With all implementation tools technically ready, the extra 12 months will provide a phased period for effective and thorough implementation.
The feed industry has welcomed the proposed one-year postponement, but how have European aquafeed manufacturers been managing the EUDR so far?
Challenges and opportunities
The EUDR represents a significant European effort to curb global deforestation by regulating trade in commodities associated with forest destruction and degradation.
“It has the potential to greatly reduce carbon emissions and mitigate biodiversity loss tied to deforestation, as companies must prove that their products are not linked to deforestation. This encourages corporate responsibility, as businesses are required to conduct due diligence to ensure their supply chains are deforestation-free, promoting transparency,” explained Guido Crolla, manager procurement, sustainability and IT, Alltech Coppens.
However, tracking commodity origins in complex supply chains can be challenging, particularly for smaller companies and smallholder farmers who may lack the resources or technology to comply.
Aquafeed companies have been working closely with their supply chains in the past year. “We have been in close contact with our supply chain partners and have seen their dedication to supplying EUDR-compliant products from December 30, 2024, onwards. Through these conversations, we have come to understand that several challenges facing the supply chain, including providing sufficient evidence to the authorities amidst complex supply chains and local legislative variances,” said Bastiaan van Tilburg, CEO of Skretting.
“In addition, many of our supply chain partners face extensive administrative requirements, and the EU’s central computer system, where this information will be entered, is still under construction. We understand that the European Commission has proposed to postpone the EUDR implementation, which, if approved by the European Parliament and Council, would result in the law being applicable from December 30, 2025. Given the current uncertainty around the timeline for full compliance, we hope the European Parliament and Council will reach a final decision soon,” van Tilburg said.
“There’s consensus across Europe on the EUDR’s aims, but the issue has been its rapid initiation without adequate guidelines, which left the industry unprepared—especially the supply chain. Soy farmers didn’t fully understand the EU’s expectations, and soy importers didn’t have the complete picture. I believe it’s a wise choice to pause the implementation to ensure we approach this in the right way. The entire supply chain can adapt to it. I’d rather have a well-planned solution implemented a bit later than rush into the wrong one,” said Henrik Halken, group vice president of Aller Aqua Group.
Impact on global commodities’ market and prices
Would EUDR have an impact on the global commodities market? “The EUDR could create tension with countries heavily dependent on these commodity exports, like Brazil and Indonesia, where it may be seen as an economic threat. In regions with weaker environmental governance, producers may face economic challenges if they cannot meet the new standards, potentially worsening social inequalities. However, it also provides an opportunity for these regions to adopt sustainable farming and logging practices to maintain access to the European market,” Crolla said.
“Countries and producers that cannot comply with the EUDR’s strict requirements may lose access to the lucrative EU market, which could shift trade flows. Non-compliant countries may pivot toward other markets without similarly strict environmental regulations, such as Asia or the Middle East. Still, the EU’s influence may eventually encourage other global markets to adopt similar measures, limiting these alternatives over time,” Crolla said.
However, EUDR is not expected to affect feed prices. “We are continuously focusing on more sustainable resources and circular raw materials and keeping the same high-quality feeds as we are known for. Circular raw materials are sourced from waste or by-products, as defined by the EU waste framework directive. For example, in 2023, 56.2% of all the raw materials we used were circular and restorative raw materials, and we aim to increase this to at least 75% in 2030,” Crolla said.
Current implementation by aquafeed manufacturers
Aller Aqua was one of the first companies to comply with EUDR by halting the use of South American soy in 2020. The company’s three European feed mills use only European soy. Recently, they released new carbon footprint calculations for aquafeeds with EU soy. “The new result is calculated using European-produced soy compared to Brazilian soy. Using only regionally produced soy in 2023 in our European factories, we have achieved 32% CO2 savings, not 17% as previously assumed,” said Halken.
At Alltech Coppens, EUDR guidelines have been in place for years. “Previously, we used only Pro-Terra Certified Soy products, and for the last year, we have been completely soy-free. For over a decade, we have also been palm oil-free. As we are always trying to go one step further, our code of conduct for business partners already includes clauses on deforestation to ensure that none of our products are involved in any deforestation activities. Without signing, agreeing, and showing proof of this code of conduct, a supplier is not able to do business with us,” Crolla said.
BioMar has published a Vegetable Ingredients Position Statement which outlines its commitment to sourcing deforestation and conversion-free soy and palm. All BioMar business units are required to fulfill this statement by January 2025. “Despite the recent proposal to delay implementation of the EUDR, our preparation is ongoing in expectation of it coming into force,” said Lindsay Pollock, global sourcing sustainability lead at BioMar.
BioMar will not accept high-volume plant ingredients or high-risk ingredients (soy and palm) from cropland deforested or converted from natural habitats after December 2020 (cut-off date), requires traceability documentation for each delivery and targets to have 50% of BioMar’s raw materials consisting of either circular or restorative ingredients by 2030.
Skretting's parent company Nutreco fully supports the goals of the EUDR to reduce the risk of deforestation by ingredients used in animal feed. “As a user of EUDR-relevant products, ensuring deforestation-free status aligns with our own sustainability agenda and enables us to offer feed products in the EU and Norway that do not contribute to deforestation. The EUDR-relevant products for Nutreco are mainly soybean meal, soybean oil and several palm products, which are mainly used in our livestock businesses. While soy protein concentrate (SPC) is not listed in the regulation, our European aquafeed businesses are committed to sourcing SPC that is certified deforestation- and conversion-free,” van Tilburg said.
Other key measures needed
Addressing global deforestation requires a multi-faceted approach beyond regulations like the EUDR. A broader strategy is needed to tackle the root causes of deforestation effectively.
“Combating deforestation calls for a combination of regulatory, financial, technological, and social interventions. While policies like the EUDR are important, they must be complemented by sustainable development, international cooperation, corporate responsibility, and consumer awareness. A holistic approach that addresses the underlying causes of deforestation—such as poverty, governance, and unsustainable demand for commodities—is crucial for achieving long-term forest conservation goals,” Crolla said.
“In the EU, we can implement this type of regulation, but we need other regions to align with our efforts. While we're ahead in the EU, we can’t tackle this challenge alone,” said Halken. He sees some clear obstacles. “In Africa, people spend 50% of their income on food, compared to 13% in Europe. When prices rise, like they did after the war in Ukraine began, the impact is severe. In Europe, we can afford to ask for higher standards on top of basic supply and price needs, but in other regions outside the EU, that isn’t always feasible.”
Increasing protein production in Europe, such as local plant proteins and novel ingredients, is another part of the solution. “However, the whole European industry – across pig, poultry and cattle farming – cannot source all its soy from within Europe. Europe is not soy self-sufficient. Though soy production is gradually increasing alongside other protein crops such as fava beans, there is still a long way to go,” Halken concluded.
