WASHINGTON, D.C. – The National Alliance of Forest Owners (NAFO) is deeply concerned with the results of the European Commission’s “review” of its Deforestation-free Regulation (EUDR). The Commission’s simplification package published today fails to address the concerns raised by highly-forested, low-risk countries like the United States, where impacts of the law have not been assessed and are not well understood in the EU.
Unfortunately, the review and simplification package fails to deliver the relief that forest owners and operators in low-risk countries outside the EU, like the United States, urgently need in order to meet compliance requirements. The irony is clear: a law intended to reward sustainable sourcing should create a competitive advantage for sustainable forestry. Instead, the EU risks cutting off the very sustainable suppliers it says it wants. All the while, the EU has acknowledged the issues with the law but only addressed them for supply chains within its borders.
Although the EU failed to conduct an impact assessment of how EUDR requirements would affect low-risk supply chains, early implementation has already revealed a deeply troubling picture across the U.S. forest products supply chain, where compliance is largely already in effect. A recent survey1 of the U.S. forest products supply chain confirms that the Regulation is already generating significant market disruption and creating deforestation risk in the United States, despite the country’s low-risk designation. The early data show that the current EUDR regulation does not address sustainability, but rather it sorts sustainable suppliers into two groups: large operators that can afford to comply, and those with limited resources who are exiled from the marketplace.
Although private forest landowners – including Tribes and millions of small family landowners – supply 90% of U.S. wood and fiber, they are already being shut out of markets due to the Regulation’s compliance burdens.
The Commission claims to have reduced annual EUDR compliance costs by 75% through the simplifications announced today and those adopted in December 2025. However, none of these amendments offer practical relief for forest owners based in low-risk countries outside the EU. For instance, simplified compliance for micro and small primary operators is only available to those directly placing products on the EU market, excluding virtually all producers located outside the EU.
“The Commission made it abundantly clear that they never intended to do a thorough review of the law, and as a result, the simplification package does nothing to address fundamental flaws that create enormous challenges for modern, sustainable forestry,” said NAFO Chief Strategy Officer Kate Gatto. “A law designed to combat deforestation is threatening the very sustainable forestry systems that keep American forests standing. The Commission must delay EUDR enforcement for forest products from low-risk countries until the Regulation is genuinely workable for sustainable forestry.”
Since today’s announcement fails to deliver the simplification needed for low-risk countries outside of the EU, we call on the Commission to complement today’s announcement with a further simplification package aimed at low-risk country operators outside the EU.
To avoid another rushed process, we recommend that the Commission delay full enforcement of EUDR for forest products from low-risk countries until EUDR impacts have been adequately studied, and simplification options for low-risk countries have been addressed. The EU Timber Regulation (EUTR) can continue to apply in the meantime.
This delay would allow the Commission to:
- Conduct a thorough impact assessment focused on highly-forested, low-risk countries, including the United States, that examines effects on small family forest owners and Tribes, low-risk forest product supply chains, and landowners and operators selling into the global market, not only those placing products directly on the EU market.
- Simplify geolocation and data-sharing requirements for forest owners. Current EUDR requirements impose an unjustifiable and disproportionate burden on smaller landowners and bear no relationship to how forest product supply chains operate in practice.
- Enter into formal dialogue with low-risk countries, including the United States, to fully understand the on-the-ground challenges created by this Regulation and work collaboratively on durable solutions that preserve the intent of the law.
NAFO shares the EU’s commitment to combating global deforestation and promoting sustainable forest products, and we remain committed to helping the Regulation succeed.
We call on the Commission, the European Parliament, and the Council to deliver the targeted adjustments needed to ensure EUDR achieves its environmental objectives without sidelining the sustainable producers and low-risk supply chains that help deliver the very outcomes EUDR is intended to promote.
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The National Alliance of Forest Owners (NAFO) is a U.S. advocacy organization committed to advancing policies that ensure our working forests provide clean air, clean water, wildlife habitat and jobs through sustainable practices and strong markets. NAFO members own and sustainably manage 44 million acres (18 million hectares) of private working forests – an area twice the size of Portugal. These forests are managed to provide a steady supply of timber. NAFO’s membership also includes state and national associations representing tens of millions of additional acres. Private working forests in the U.S. support 3.9 million jobs. Private working forests – which provide 90% of U.S. timber harvest for wood and fiber – also account for 80% of our total net forest carbon sequestration and nearly half of our forest carbon storage. Learn more at nafo.org