Feedback reference
Submitted by
Haji Aliasak Bin Haji Ambia
User type
National Association of SmallHolders (NASH)
Organisation size
Large (250 or more)
Country of origin

The published EU Roadmap on tackling deforestation and forest degradation is the latest in a long series of EU initiatives aimed to regulate and control palm oil imports from the developing world. The EU’s environmental and sustainability agenda is the latest tool for controlling the developing world. The EU must stop, and recognize that it lacks the moral authority to impose such control barriers.

Every initiative or proposal contained within this Roadmap amounts to the same objective: the EU plans to disenfranchise 650,000 Malaysian small farmers – and millions of other small farmers round the world – by imposing discriminatory restrictions on palm oil exports. Enough is enough.

This is the context in which the EU Roadmap was prepared. Small Malaysian farmers of palm oil are sustainable: European countries – who already deforested their own continent to incredible levels – do not have the moral authority to lecture small farmers in Asia or Africa. Similarly, the EU does not have the moral authority to impose restrictions.

NASH provides the following feedback to the Roadmap proposals:

1.Building effective partnerships with producing countries to support the uptake of sustainable practices: The EU is not needed. Malaysia is a recognized world-leader in palm oil sustainability, and forest conservation more widely. The Malaysian Government maintains 54.9% of its land as forest area, which is almost double the EU’s average forest area. Furthermore, palm oil is the world’s most land-efficient oilseed crop and has the lowest environmental footprint of any oil-bearing crop.

2.Promoting sustainable supply chains: It is patronising, and false, to suggest that only the EU can provide this. The Malaysian Government has introduced the Malaysian Sustainable Palm Oil (MSPO), a world-leading sustainability certification based on ISO standards. The EU should formally recognize MSPO’s role in promoting sustainability.

3.Helping smallholders: Palm oil has been a great poverty alleviation tool for Malaysia. The EU Roadmap’s proposed action, targeting palm oil, would have the opposite effect and hurt small farmers. More than 650,000 Malaysian small farmers and their families depend on palm oil. Any discriminatory EU action plan would harm the incomes and livelihoods of these families.

4.Strengthen international cooperation with other major consumer countries to ensure sustainable supply chains: All Malaysian palm oil exported to the EU meets strict criteria for sustainability as set out by existing EU rules. MSPO rules will also be mandatory in Malaysia, to guarantee sustainability.

Any EU actions that target palm oil will be met with trade response from producing countries. The EU should pull back from its provocative and protectionist stance over palm oil that could impact billions in exports.

The Malaysian Government has already warned that it will “take retaliatory actions on bilateral trade and other ongoing collaborations”.

5.Building EU policies that can help prevent tropical deforestation and forest degradation: With palm oil, more oil is produced per hectare, substantially less fertiliser is used, lowest energy input needed and fewer pesticides are needed, per tonne of oil produced. If anything, EU policies should target the use of other oilseeds that are more damaging to the environment, such as rapeseed and sunflower.

Many studies, including the EU’s very own research have concluded that palm oil is a very small contributor to global deforestation, compared to beef and livestock, and other commodities such as maize.

o Where is the EU’s Delegated Act targeting beef, or soybean?
o Why has the European Parliament not called for a total ban on maize, or beef?
o Why is the European Commission promising to import MORE soybeans, despite the proven environmental impact?

The anti-palm oil focus of the EU’s Roadmap is unjustified, unscientific, and uneven.

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