Official Report: Minutes of Evidence

The Chairperson (Ms Ferguson): I welcome, from the Department of Agriculture, Environment and Rural Affairs, Brian Dooher, Chief Veterinary Officer; and Catherine Fisher, director of the Windsor framework implementation directorate.

I invite Catherine and Brian to present their evidence. Happy new year to you both. When you are ready, please make your presentation.

Ms Catherine Fisher (Department of Agriculture, Environment and Rural Affairs): Thank you, Chair and members, and happy new year to you, too. Thank you for the invitation to come to speak to you today.

As you noted at our previous attendance on 11 December, the EU deforestation regulation (EUDR) refers to regulation (EU) 2023/1115, which is:

The aim of the regulation is to reduce deforestation and forest degradation.

By way of a brief reminder, the EUDR lays down rules on the placing and making available on the Union market, as well as on the export from the Union, of relevant products that contain, have been fed with or have been made using the following seven commodities: cattle, cocoa, coffee, palm oil, rubber, soya and wood. In particular, the EUDR aims to ensure that those commodities and relevant products are placed or made available on the EU market or are exported only if they are deforestation-free, have been produced in accordance with the relevant legislation of the country of production and are covered by a due diligence statement.

The EUDR was originally delayed by one year through regulation (EU) 2024/3234. The present Act was subsequently proposed on 21 October 2025 to further delay the application of the EUDR by six months and introduce several simplifications. In November 2025, the EU Council and Parliament voted to amend the proposal further in order to increase the application delay to one year and to add further simplifications. A provisional political agreement was reached on 4 December 2025. On 17 December, the European Parliament adopted the targeted amendments to the EUDR. The regulation that is being considered today — regulation (EU) 2025/2650 of 19 December 2025, which amends regulation (EU) 2023/1115 as regards certain obligations of operators and traders — was published in the Official Journal of the EU on 23 December 2025 and entered into force three days later.

Regulation 2025/2650 enforces the additional one-year delay to the application of the EUDR. That will now apply to large and medium-sized enterprises from 30 December 2026 and to micro and small enterprises from 30 June 2027. As noted at our previous attendance, the regulation also introduces further simplifications to the EUDR. Only operators that first place relevant products on the EU market are now required to submit due diligence statements. Furthermore, only the first downstream operator in the supply chain is responsible for collecting the reference number of such statements. Micro and small primary operators are required to submit only a one-time, simplified declaration and will receive a declaration identifier that will be sufficient for traceability purposes. They may also replace the geolocation of plots of land in their simplified declaration with a relevant postal address.

Other key points of note include that certain printed products, such as books, newspapers and printed pictures, are no longer in scope of the regulation and that the European Commission must conduct a simplification review and report by 30 April 2026. That will evaluate the EUDR's impact and administrative burden on micro and small enterprises in particular and may, where appropriate, be accompanied by a legislative proposal. Finally, the general review date for the EUDR is postponed by two years, to 30 June 2030.

The EUDR and regulation (EU) 2025/2650 are primarily focused on the trade of goods and their impact on global deforestation. They are therefore reserved, with responsibility sitting with the UK Government. The Department for Environment, Food and Rural Affairs (DEFRA) leads on the EUDR, and DAERA does not currently have a role in its application. DEFRA has advised that the UK Government are considering how best to implement deforestation policy across the UK; that DEFRA is aware that businesses require certainty on their approach to deforestation policy; and that it will provide more guidance for businesses as soon as possible.

The UK Government have not yet clarified the extent of the application of the EUDR in Northern Ireland. Given the current lack of clarity, the delay to its implementation that is applied through the regulation is welcome.

The further 12-month postponement will give traders and operators additional time to prepare in time for DEFRA to confirm the relevant arrangements. It does not appear likely that the application of the amending EU Act would have a significant impact specific to the everyday life of communities in Northern Ireland in a way that is liable to persist. In the short term, there would be no change to the current position, as the regulation delays the application of obligations pursuant to the EUDR.

Furthermore, the simplifications introduced are likely to be welcomed by local businesses. Although DAERA has not undertaken any engagement on the issue, we expect that reaction, given the potential to reduce the reporting requirement and administrative burden. It appears likely that not applying the amending EU Act would have a significant impact specific to the everyday life of communities in Northern Ireland in a way that is liable to persist. If the amending EU Act were not applied, obligations pursuant to EUDR would be delayed in the EU but not in Northern Ireland. That would place operators and traders here at a disadvantage compared with EU member states, third countries and GB.

I hope that you found that overview useful. I thank you for your time and welcome your questions.

The Chairperson (Ms Ferguson): Thank you, Catherine. Brian, are you going to present?

Mr Brian Dooher (Department of Agriculture, Environment and Rural Affairs): No, that was the overview, and I am happy to take questions as required.

The Chairperson (Ms Ferguson): I will open it to the floor. I remind members that their questions should focus primarily on the published replacement EU Act under consideration today.

Mr Buckley: Obviously, the regulation is about delaying the EU deforestation regulation. I suppose that that probably justifies some of the concerns that I and others have expressed regarding the original and overarching legislation. The Committee was not in situ when that was passed. I had concerns about supply chains, particularly for businesses that source from global markets and GB, and UK food security.

I want to ask a question that is specific to Northern Ireland. You said that DAERA has not consulted stakeholders on the regulation; I think that I am right in saying that. Is it your intention to do so?

Ms Fisher: The Department does not currently have a role in the EUDR, so we have passed on any queries that we have to DEFRA, because it is leading on it.

Mr Buckley: It is not clear who would be the competent authority in Northern Ireland to enforce the EUDR, were it to be put in place. Do we know or have any more clarity on who that might be?

Ms Fisher: No. We await clarification from DEFRA on the application of the EUDR and who will be the competent authority.

Mr Buckley: Thank you.

Dr Aiken: My question follows on from Jonathan's. Information on that is in Hansard, because we asked a question about it previously. I think that you said that you would engage with stakeholders when you saw the formal proposals.

Ms Fisher: The formal proposal?

Dr Aiken: When it was published.

Ms Fisher: DEFRA said that it would engage with stakeholders.

Dr Aiken: No, you — DAERA — did.

Ms Fisher: We will engage with stakeholders to —.

Dr Aiken: Hansard states:

You then said that you will engage when you have seen the formal proposal.

Ms Fisher: We will engage with stakeholders to update them and let them know that the application of the EUDR has been delayed by one year. That is the only update that we have at the moment. We have put all the stakeholders on a list, and we will update them to let them know that it has been delayed.

Dr Aiken: My apologies. I did not read it that way. I am sorry about that.

Ms Fisher: No problem.

Mr Brooks: You have taken concerns from stakeholders and passed them to DEFRA: how does that align with your assessment of what impact it will have? Was it just a case of taking something and handing it over to DEFRA, or have you analysed those concerns and considered them in coming to your conclusions?

Ms Fisher: No, they were passed on to DEFRA because DAERA does not currently have a role on the EUDR.

Brian, do you want to add anything on that?

Mr Brooks: You have given an impact assessment on the regulation, and you know that stakeholders in Northern Ireland have views on it, but, in order to keep yourself clean of responsibility — that is what I hear — you are not considering those concerns. It seems negligent to me that the Department is aware of concerns in the industry but will not consider them in coming to its conclusions. The conclusions may well have been the same. My concern is that, if you are aware of concerns, why would they not inform the view that you come to?

Ms Fisher: The impact assessment relates to the delay of the application of the EUDR, and we described the impact of that delay.

Mr Brooks: I understand that, but you have deemed it relevant —.

Ms Fisher: It is not about the application. The concern from stakeholders has been about the application of the EUDR itself, and we have passed those concerns on to DEFRA. The Department has no functions on this, so we have passed the concerns on and —.

Mr Brooks: You have deemed it relevant to tell us that you have heard those concerns and passed them to DEFRA, but the Department has almost been like a messenger in that it has taken those concerns and handed them over but has not taken those views into consideration in informing its view.

Ms Fisher: We have passed them on because the matter is reserved. It is not a matter for DAERA to consider. However, we have engaged with stakeholders. Brian has attended meetings with stakeholders.

Mr Dooher: We know that it is a reserved matter and sits over there at the minute, and the applicability of it here will be resolved in due course by the competent authority, as you touched on. We are waiting for clarity on that. Aside from that, I have had contact with a number of stakeholders — basically, the meat processors and the Grain Trade Association — and they raised their concerns about what they need to do to get prepared for it. We have passed those concerns on to DEFRA similarly.

I attended one stakeholder meeting with DEFRA and the meat processors that looked at what potentially will be required here going forward and what scoping work can be done in advance so that we are ready to move once we know all those things, including who the competent authority will be and whatever else. Provisional work has been done on that, but that is as far as it has gone so far.

Mr Brooks: I am reassured that that engagement has gone on, and I hope that it informs some of your thinking on this. I understand that the regulation is minor compared with the overarching legislation, but, given the lack of clarity around how it will be applied in Northern Ireland, has the Department considered asking the UK Government to request a stopping of the clock on it?

Mr Dooher: At the minute, no. We are waiting for clarity. The matter primarily sits with the UK Government, as Catherine touched on. The medium and larger operators are planning for the end of this year and the following year, which will be summer 2027, and simplified declarations are proposed for micro and small operators. If the regulation becomes applicable in Northern Ireland, a simplified declaration should be fairly achievable. Those should not be too big to achieve.

The other side of it is the grain imports. You are looking at two things. How can we get our cattle killed and on to the market? They have put simplifications there, and we are waiting for that simplification review, which is coming at the end of April, to further flesh that out. It seems fairly straightforward. If it ever comes to us — that is a question of ifs and buts — our traceability database should hold the information necessary to provide the assurances that are necessary to provide the declarations that are needed as regards the diligence statements.

The proposed simplification means the lessening of the requirements for downstream operators, taking away the need for meat processors to put anything else forward. On the basis of what we see, it should be deliverable in the time frame that we have. It is early in that time frame, and we are at the stage of scoping out, and it depends on that. We are waiting for clarity from DEFRA, because it is its responsibility at the minute, and, when it decides to tell Northern Ireland who is the competent authority for enforcing it here, we will take that forward.

Mr Brooks: I accept that. As I say, I was heartened to hear about that engagement, because, even though DEFRA is the authority on this, it is important that our local Departments, which have knowledge of and contacts in Northern Ireland, engage in that. I am glad to hear that that has been happening on some level.

Mr Martin: Thanks for coming, folks. Catherine, you were at the Committee before Christmas, and Dr Aiken asked this question:

You said:

Brian, I was listening to your earlier comments. Was there one meeting or a couple of meetings? Given what Catherine said at the previous Committee meeting, what has been your level of engagement?

Mr Dooher: The meat industry had contacted me. We have a fairly close relationship because we work daily with the meat sector. That was not untoward; it was just an agenda item in a meeting of many agenda items. It was about how we would prepare for the EUDR because, obviously, industry representatives were getting questions from their retailers about how they would comply with the EUDR. That is why we, as Catherine said, had to forward those queries up to DEFRA — because of those responsibilities.

Aside from that, we had one subsequent meeting with DEFRA and the meat industry here at the Northern Ireland Meat Exporters' Association (NIMEA) and a few GB bodies, including the Animal and Plant Health Agency (APHA). They are basically scoping out proposals on what, they think, will have to be done to deliver assurances with regard to the due diligence statements that are needed. It seems to be achievable at a very high level. However, we have not got the proper detail yet. At the minute, what we see is that it should be deliverable.

Mr Martin: I do not want to stray from the EU Act that we are discussing, which is about the extension. Do stakeholders have concern about the original proposal? Is that where their concerns are?

Mr Dooher: Their concerns were not so much about the proposal as about how they would meet the requirements, what requirements would be placed on them and what information they would have to provide. That was before we got any extension/simplification. It was a lot more onerous at that time. With the more recent version, the simplification of it lessens our concerns a bit. However, we are still waiting for the detail, ultimately, on the whole thing.

Mr Martin: As regards your engagement with DEFRA — I asked Catherine these questions at the time — the information that we got from DAERA was a three-page document with a lot of quotes from DEFRA, really. I was a little frustrated about that. I understand the context of it — that DEFRA is the lead authority — and the nature of it being a reserved matter. Have you or the Minister had any direct engagement with the Secretary of State for Environment, Food and Rural Affairs on that proposal or the EUDR's impact?

Mr Dooher: I have had no direct contact, and nor has the Minister, as far as I am aware, from the Secretary of State regarding the applicability of the deforestation regulation across Northern Ireland at the minute. However —

Ms Fisher: Sorry to cut across you. There has not been contact with the Secretary of State, but Minister Muir meets Baroness Hayman of Ullock, the Parliamentary Under-Secretary of State at DEFRA, regularly. He has raised the concerns that he has received from stakeholders and has made the point that stakeholders need urgent clarity on the application of the EUDR in Northern Ireland. He has not raised it with the Secretary of State, but he has raised it in numerous meetings with DEFRA Ministers.

Mr Martin: Catherine, do you feel confident that the Minister has raised the issue of clarification on the competent authority with the Under-Secretary of State?

Ms Fisher: Yes. He has raised the issue of clarification. We are waiting to hear about that. DEFRA Ministers have assured us that they will give us and stakeholders that information as soon as it is available. At the moment, they are considering the approach to deforestation across the UK. We are waiting for that as well.

Mr Martin: It is not necessarily a criticism of you or of DAERA particularly, but that still sounds quite vague when we are trying to get a level of detail around that. I remember reading a quote to you from the Agriculture Minister:

It still seems quite vague and as though we are staring into something when we do not know the context or what the outcomes will be. Anyway, thank you very much for your evidence.

Mr Kearney: Thanks for coming in, folks. If I have understood you correctly, you say that you welcome the delay of 12 months because it is likely to provide additional clarification: is that right?

Ms Fisher: Yes. It gives time for businesses and for us to get clarification from DEFRA on the applicability.

Mr Kearney: OK. Can we take it that engagement with processors is routine and that the discussions that you have had are part of routine business?

Mr Dooher: NIMEA is a stakeholder that we meet routinely on a number of fronts. It is there and available for discussion as and when required.

Mr Kearney: Thank you. Has the outcome of those meetings, including the engagement on this issue, been relayed to DEFRA?

Mr Dooher: Yes. As Catherine highlighted, the meetings with the Ministers, Baroness Hayman included, provided the clarity required by industry.

Mr Kearney: That is first-class. Do you have confidence in the robustness of DAERA's systems to handle the outcome of the 12-month period and the new processes and systems that are likely to be put in place?

Mr Dooher: Yes, on the basis of what I have seen so far. However, I have not had the detail yet. If it is to be a one-time, simplified declaration from farms and small and micro operators, that should be achievable and fairly straightforward. We should have the information there. The information should already be on our databases in Northern Ireland for all those small and micro operators. We will have to look at the medium-sized operators and where that line is drawn, potentially, and what moves from small to medium. That may be a wee bit more onerous for some of those people, including the bigger farmers. We are waiting for clarification of that matter.

Mr Kearney: As we understand it at this time, however, the direction of travel is towards simplifications.

Mr Dooher: That is what it is pointing to. The EU is carrying out a review and is to publish a report at the end of April 2026 on that simplification, particularly in relation to the small and micro operators.

Mr Kearney: That is everything, Ciara, thank you.

Mr Buckley: Thank you for letting me back in, Chair.

The overarching EUDR legislation obviously predates the Committee. Were there any conversations about that with the industry? You can talk about it now in the Committee and through other systems that have been put in place, but, before that, were there any opportunities for stakeholder engagement?

Mr Dooher: The EUDR had always been referenced as being on the horizon. The detail was not there, however, nor was there any knowledge of how it would apply in Northern Ireland. As we touched on, it was a reserved matter. It never got to the point of detailed discussions on our side.

Mr Buckley: In any discussions — I have seen it before — the industry's hope is that, if it has a problem with the overarching legislation, the delays enable those problems to be solved, yes? Am I right in that theory? Therefore, those who wish to raise concerns about it will use the extension to point to those concerns and whether or not they can be overcome. That is a fair point. Those who are engaging now and raising their concerns about the original overarching legislation are using the extension period to voice their concerns about it.

Mr Dooher: Everybody wants clarity on the requirements that will be placed on them and how they are meant to comply with those requirements.

Mr Buckley: I have asked you about that because, sometimes, we get fixated on the principle of talking about the specific issue, which is the delay, rather than what that delay is about or why the industry is concerned about it or having problems with it. I will go back to David Brooks's point. Given your engagement with processors and others, are you able to simplify for me how those concerns manifest themselves? Is it concern about costs, direct or indirect, or is it about bureaucracy? Are there concerns around supply chains? Are you able to distil what that concern looks like, Brian?

Mr Dooher: I will take it back a step. They want clarity. They know that the EUDR is coming in. The EUDR is about biodiversity, climate change, the impact of deforestation and any products that can cause that. That is where it comes from. They know that they will have an obligation placed on them to ensure, before they place products on the market, that those products are compliant. They want clarity on what they are required to do; the list of things — a, b, c and d — that they need to do; and what checks will be done on them to ensure that they comply. That is at a high level, because we have not got into the detail yet, until these things have come out here.

Mr Buckley: If I am getting you right, the concerns are about how people comply rather than the actual impact. If we take that downstream, what are the changes for a specific processor that raise concerns about a cost impact or a supply chain impact?

Mr Dooher: It is unknown. It is as simple as that. It was unknown at the time. The delay, the proposed simplifications and the simplified declarations will definitely ease their minds. They are waiting until April to get the final report from the Commission. Whatever happens, that is when they really have to get the ball rolling. From their point of view, they are planning a year in advance. They want to get ready. They want as much time as possible to get systems in place to provide assurances about the product that they are putting on the market. That is what they want. The more time and clarity we give them, the better.

Mr Buckley: Thank you.

Dr Aiken: I want to get my head around this. Everybody is still seeking clarification because we do not know what will happen until April 2026, when the final detail will come out. What we are being asked to do here is approve regulations that have not been finalised yet.

Ms Fisher: The regulations have been finalised.

Dr Aiken: But the detail —

Ms Fisher: The regulations on the delay and the simplifications that will be introduced have been finalised. If the review at the end of April is accompanied by legislative proposals, there will be consideration of a new regulation to introduce further simplifications.

Dr Aiken: So we do not know yet what the simplifications are likely to be.

Ms Fisher: We know what they are currently. They may be subject to change in a few months' time on the basis of the review.

Dr Aiken: We do not know yet. Basically, if I were somebody who was relying on this, I would not know until April what the changes were likely to be.

Mr Dooher: You would know broadly what those were from the most recent regulation. We will have simplified declarations in place for small and micro operators, and there will be no requirement on downstream operators — basically, the meat factories — to do anything further, because the person putting the animals in there will have to make the simplified declaration.

Dr Aiken: They cannot do any implementation until after April, can they?

Mr Dooher: They do not know definitively yet what they will have to do and whether there will be anything further. I suppose that that is what they are waiting for.

Dr Aiken: To summarise, the regulation is in, but we just do not know what it will look like.

Mr Dooher: We have an idea of what it will look like operationally after implementation, but we are still in the early stages.

Dr Aiken: There is no real point in asking for any more information because you will not know anything until after April.

Mr Dooher: We will know something. You would like to think that, over the next number of months, DEFRA will put in place systems that are broadly along the lines of what we have. Hopefully, there will be time to do a bit of preparatory work now so that the IT systems are able to adapt to whatever comes down the road. That is the ideal scenario. The sooner we get clarity, the sooner we will be in a position to act.

Dr Aiken: OK. Thanks.

The Chairperson (Ms Ferguson): There are no other questions from members. I thank Brian and Catherine for their attendance here today.