Feedback reference
Submitted by
Michael Rice
User type
Non-governmental organisation (NGO)
Both ENDS jointly with Forest Peoples Programme, FECONAU, FAPI, SESDev, SDI, Pusaka, & OKANI
Organisation size
Small (10 to 49 employees)
Transparency register number
Country of origin

The feedback in the ATTACHED DOCUMENT is jointly submitted by eight civil society and forest peoples’ organisations from Europe and tropical forest countries.
A summary of key points is provided below.

While we support “a more coherent and comprehensive approach to the problem”, we are concerned by the unreasonably limited scope of the Roadmap’s so-called ‘comprehensive approach’. Modifying existing EU policies and supporting existing commitments is woefully inadequate to reverse the rising trend of EU contribution to global deforestation. This approach ignores the fact that existing policies and tools, as well as voluntary market mechanisms and certification schemes, have failed to slow global deforestation or prevent systemic landgrabbing and human rights abuse linked to trade in forest-risk commodities. The preference for relatively easy options of tinkering with existing initiatives and avoiding legislative intervention also suggests an alarming underestimation of the scale of the problem and disconnect with Commission’s policy-making mandate.
The Feasibility Study concluded that “a more coherent and comprehensive EU approach” acting on multiple levels to address the problem from several angles is needed that new legislative measures combined with non-legislative measures (‘Option C’) “should have the greatest impact”. The present Roadmap disregards options for legislative initiatives, adopting an approach consistent with ‘Option A’ described in the Feasibility Study as being least effective, with the lowest likely contribution to the objective. This low-impact approach is misguided, as many existing measures have proven inadequate.
While the European Parliament’s repeated calls for an Action Plan on Deforestation and Forest Degradation that includes legislative measures to reduce EU consumption of embodied deforestation and forest-risk commodities are acknowledged, the Roadmap rejects the policy-making mandate conferred by the Parliament. Instead of the least-effective ‘Option A’, the Roadmap should propose a substantive response to the Parliament’s repeated calls for regulatory measures and pursue Action Plan that combines improving existing initiatives and developing necessary legislative interventions.

Global agricultural production is intricately linked with patterns of social injustice, environmental damage, displacement, violence and murder of local and indigenous people, their leaders and human rights defenders. It is not clear what measures are proposed to eliminate these negative impacts of EU trade and consumption, nor is it clear how EU trade, investment and development cooperation will be aligned with EU human rights commitments and treaty obligations. While we support improving land governance, livelihoods and sustainable agriculture and forestry practices in producing countries, such initiatives must prioritise protection of the rights of local communities and ensure that EU companies do not contribute to human rights violations abroad.
A rights-based approach would support efforts towards halting deforestation and requirements on EU enterprises to obtain and verify evidence of respect for the rights of local communities would enhance efforts to address local drivers of deforestation. The Roadmap should therefore adopt a rights-based approach aligned with existing EU commitments on good governance of land tenure. To ensure measures are effective, human rights and environmental due diligence obligations should be mandatory. Given formally recognised and secure tenure rights are proven to mitigate deforestation-risks, the importance of secure tenure rights of local communities should also be recognised by including specific measures for “Supporting Secure Tenure Rights of Forest Peoples”, such as targeted assistance for land and livelihood rights for communities in producer countries.

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