AHA working to ensure legal clarity around EUDR acceptance

AHA Statements should provide all the due diligence data, including geolocations, required by EUDR. Nevertheless, to enhance legal clarity, AHA is working with EU industry partners and engaging with EU Member State regulators to encourage a single correction to the legal text and to develop guidance that leaves no doubt that the county-level geolocations supplied through AHA are fully compliant.

Under the EUDR Amendment Regulation passed in December 2025 announcing the 12-month delay to enforcement, the EC was also mandated to review the legislation with a view to proposing further changes to the legal text before 30 April 2026. The one correction to the legal text we are advocating, alongside other U.S. industry groups and European industry colleagues, is to remove the phrase “within a single real estate property” from the definition of the “plot of land” for which geolocation data is required. This would remove a phrase from the definition that should never have been included in the first place, while allowing the geolocation plot to be defined more realistically as a local jurisdiction such as a county, or as a mill supply area or similar unit.

The legal case for this change is both simple and incontrovertible. The reference to a "single real estate property" in the legal text can have no legal force because it does not apply to at least 73% of global forest area. In 3 billion hectares of the world's total 4 billion hectares of forest, it is already perfectly acceptable under strict interpretation of the EUDR legal text to define the plot of land solely based on it being "homogeneous risk". All AHA is asking is for equivalent flexibility in those countries and regions where land is predominantly privately owned and therefore legitimate "real estate property".

Regrettably, the EC has so far chosen not to respond to any of our requests for a meeting to present our case, despite several approaches both directly and through intermediaries at European trade associations. This is perhaps understandable given on-going political tension between the U.S. and EU.

But we haven’t let that deter us from pushing for a legal correction that will both strengthen EUDR and provide a firmer foundation for continuing good trade relations in the forest products sector between the U.S. and EU. We are working closely with the European trade associations now leading efforts to encourage sensible reform of the EUDR – including CEI Bois (EU wood product manufacturers association), GD Holz (German timber industry federation), and the European Timber Trade Federation. All these organisations have included a recommendation equivalent to AHA’s proposal to amend the plot of land definition as part of their own submissions to the EC.

AHA is now arranging a series of meetings with the EUDR Competent Authorities in key member states, prioritising those which are either larger importers of U.S. hardwoods (Germany, Italy, Spain, Portugal, Ireland), or particularly influential in setting regulatory benchmarks across the region (such as the Netherlands).

Early indications from these meetings are that, while there are still some differences in legal interpretation, there are reasons for optimism that AHA Statements will be uniformly accepted for EUDR conformance when enforcement starts at the end of this year.

To ensure this, AHEC still has work to do to raise awareness amongst EU regulators and operators of the nature of US hardwood supply chains and the quality of the evidence provided by AHA to confirm negligible deforestation and illegality risk - which is at least as good as, and likely surpasses, that of any other regulated commodity. This effort would benefit considerably from a demonstration of widespread uptake of the AHA platform by both U.S. hardwood exporters and their EU customers.