Committee Clean Air (Comité Schone Lucht) is committed to combating harmful air pollution and the resulting health and environmental impacts, with an emphasis on biomass, combustion chains, and the climate and nature impacts of European raw material flows.

Committee Clean Air emphasizes that the EU Deforestation Regulation (EUDR) must be fully and timely in force by 1 January 2027. Further weakening or the creation of exceptions undermines the effectiveness of the regulation and increases the risk that deforestation-related products will continue to reach the European market.

1.Leather must remain covered by the EUDR
The expansion of livestock farming is one of the main direct causes of global deforestation. Between 2001 and 2022, livestock farming was responsible for approximately 42% of deforestation linked to agricultural use, accounting for forest loss comparable to the surface area of Spain (1).
Leather is directly linked to this chain, as cattle are raised for both meat and leather.Excluding leather would mean that a product demonstrably linked to deforestation falls outside the due diligence obligations of the EUDR. This undermines the objective and consistency of the regulation and constitutes a form of selective erosion of the policy.

2.Inadequate control over wood pellets
In the Netherlands, wood pellets are imported from Malaysia, among other sources, for combustion in coal-fired power plants (including RWE Amer and Eemshaven). These supply chains are partially certified via the Green Gold Label (GGL), a system developed by the sector that is not recognized under RED II or RED III.

The Netherlands Emissions Authority (NEa), together with the Clean Air Committee, states that this system relies on self-declarations and that the definition of “residual wood” leaves room for misclassification of primary wood from forests. The NEa and CSL conclude that the control is insufficiently robust (2).
This shows that voluntary certification without independent verification does not offer a sufficient guarantee for reliable origin information.

3.Necessity of supply chain transparency
Importers must be required to provide complete, verifiable documentation of origin at the forest area level, including a clear distinction between primary and secondary wood for the production of woodpellets.
This information must be accessible to regulators and civil society organizations to enable effective monitoring. Making origin data public should be considered a minimum requirement in this regard.

Conclusion
The Clean Air Committee calls for:

  • keeping leather within the EUDR;
  • avoiding exceptions that limit the scope;
  • making supply chain transparency legally enforceable.

Only in this way can the EUDR effectively contribute to reducing global deforestation.

¹ FAO / Global Forest Watch data. Global patterns of deforestation resulting from resource extraction and associated carbon emissions. https://www.nature.com/articles/s43016-026-01305-4 Chandrakant Singh & U. Martin Persson, February 2026.

² Dutch Emissions Authority (NEa) reports. See section 2.3 of the NEa study. Is the sustainability of the wood sufficiently ensured? https://www.rijksoverheid.nl/documenten/rapporten/2026/01/22/nea-onderzoekduurzaamheid-houtpellets-maleisie