The European Commission (EC) is set to publish its 'simplification' review of the EU Deforestation Regulation (EUDR), now scheduled, after two failed attempts, to take effect in December.

In December last year, the European Council and European Parliament reached a provisional agreement on a postponement and targeted revision of the regulation.

The EU's two main regulatory bodies jointly tasked the Commission with conducting a simplification review and presenting a report by 30 April this year.

Under the EUDR, all EU-based companies importing or exporting timber, cattle, cocoa, coffee, oil palm, rubber and soy materials/products must prove that they did not contribute to deforestation or forest degradation.

Following the shambolic delays and confusion created by the EC's previous proposals, the review will face intense scrutiny, not least in terms of the data and other compliance burdens imposed across the value chain.

Rubber growers, for instance, are particularly focused on the EUDR benchmarking system, which currently classifies countries as 'low-', 'standard-' or 'high-' risk of deforestation.

Many are calling for the addition of a 'no-risk' category to the regulation's country benchmarking system to help streamline the due diligence requirements of the EUDR.

Under a no-risk category, companies sourcing products from countries classified as having stable or increasing forest cover would be exempt from submitting proof that their products did not contribute to deforestation.

Further down the supply chain, tire and rubber product makers have raised concerns about IT capabilities, downstream data reporting requirements and the legal solidity of many aspects of the regulation.