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Submitted by
Siobhan Pearce
User type
Non-governmental organisation (NGO)
Environmental Investigation Agency (EIA)
Organisation size
Small (10 to 49 employees)
Country of origin
United Kingdom

EIA welcomes the EU initiative to step up action against deforestation and forest degradation as outlined in its roadmap.

Yet, EIA is concerned the roadmap states this will be a “non-legislative initiative” and alarmed at the absence of any explicit mention of binding regulatory measures such as a due diligence regulation.

EIA believes that regulation is needed to ensure ‘no deforestation’ in the EU, as recommended by the European Parliament’s 2018 resolution on forests, as highlighted in the EU’s 2018 feasibility study as the demand side action likely to have the most impact, and as called for by France in its National Strategy Against Imported Deforestation.

Given the EU is still currently lacking any binding provisions to exclude unsustainable and illegal commodities from being financed or imported by EU operators, it is critical to set such requirements.

The EU has already regulated on illegal timber, conflict minerals, and biofuels, but lacks any means to limit the impacts of consumption of unsustainable commodities more widely, despite it being a major global importer of the commodities associated with deforestation, including palm oil, soy, beef, cocoa and coffee.

While the roadmap suggest the EC plans to “increasing the coherence of existing EU policies and tools”, EIA is unaware of any existing enforceable policies at EU level that act to exclude unsustainable products from the EU market.

EIA expects any credible EU policy initiative seeking to eliminate deforestation linked to its consumption to be predicated largely on binding measures to exclude from its market products produced in lieu of deforestation.

EIA suggests the initiative addresses the following actions:
• Enactment of a due diligence regulation: requiring compliance with clear defined legality and sustainability criteria that ensure commodities imported into and financed by EU companies do not cause any deforestation, utilising widely agreed ‘no deforestation’ standards already adopted by numerous companies, such as the High Carbon Stock Approach.
• Uptake of public procurement policies: the UK adopted a public procurement policy for palm oil in 2012 requiring it to be certified as sustainable. While this was encouraging, the debate has advanced beyond certification, and France has outlined it will adopt a ‘zero deforestation’ public procurement policy. Further support and uptake of public procurement policies by EU Member States must be supported.
• Encouragement of action in other consumer markets: the EU should leverage its bilateral coordination mechanisms to ensure they work with other major consumer markets, like China, India and the USA, to increase regulatory demand from those countries for sustainable commodities that do not contribute to deforestation, in recognition that halting deforestation is a global goal.
• Support to producer countries and smallholders: support to producer countries is needed to assist in addressing illegality, governance reforms and in ensuring real smallholders have access to markets.
• Inclusion of sustainability provisions within trade agreements: trade agreements between the EU and producer countries should include strong sustainability provisions and support for policies that halt deforestation.

EIA appreciates that a core objective of the EU’s proposed initiative will seek to “promote sustainable value chains’” and believes this must include as a minimum the exclusion of unsustainable value chains.

Similarly, while the exclusion of commodities produced in lieu of illegal deforestation must be a central part of any long-awaited EU initiative, limiting such regulation to only require legality, without requiring compliance with defined sustainability standards that that exclude deforestation, would be too little too late to enable EU policy aspirations to be met.

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