Deforestation Regulation

It is very concerning the wide divergence found between private certificates ensuring deforestation-free meat supply-chains and other independent assessments. For instance, JBS S.A, the largest meat processing company in the world by sales, has been under increasing scrutiny in Brazil and abroad due to growing operations in the Amazon and potential links to deforestation.

To meet the EU’s climate goals, live up to the Green Deal's aspirations, and ensure a habitable planet for future generations currently threatened by catastrophic and irreversible climate change, Europe must urgently act to protect the world’s forests. Addressing energy and transportation contributions to the current climate crisis will not be enough, unless forests are also taken into account.

1 ‘Promoting imported products and value chains that do not involve deforestation and degraded forests’ through private standards as mandatory labelling are measures that become the moment of its application to an unjustified obstacle or trade restriction.

Filed in Spanish · English published by the European Commission

Summary New Zealand supports the work that the European Commission (EC) is undertaking to minimise the risk of deforestation and forest degradation associated with products placed on the EU market. We do however have some suggested inputs into the formulation of any eventual measures that the EC undertakes on this subject.

Agriculture must be made sustainable. Measures should focus on promoting sustainable standards to reduce forest degradation and deforestation. It is important to consider the importance of sustainability certification schemes for production and supply chain.

Filed in Spanish · English published by the European Commission

The European State Forest Association (EUSTAFOR) welcomes the Commission Communication from July 2019 that tackles deforestation and forest degradation – reducing the impact of products placed on the EU market. The protection of World’s forests and reversing of negative trends in deforestation and forest degradation globally has been a topic of international forest policy debate since at least the Rio Earth Summit…

We warmly welcome this initiative by the European Commission (EC) aiming to minimise the EU’s contribution to deforestation and forest degradation worldwide. In order to achieve this aim to the highest extent possible, the EC must introduce binding legislation related to Due Diligence on Human Rights and the Environment for companies placing products on the EU market.

Swedish Forest Industries Federation (SFIF) welcomes the opportunity to give feed-back on this initiative. There are many drivers of global deforestation, but the expansion of agriculture is the most important one. This expansion can be divided in two parts. One is global demand for agriculture commodities such as palm oil, soya and beef.

The National Wildlife Federation welcomes the opportunity to provide feedback on ‘Minimising the risk of deforestation and forest degradation associated with products placed on the EU market’. While we are a conservation organisation based in the Unites States, we support evidence-based and pragmatic solutions to deforestation driven by commodity supply chains around the world, which frequently involve US…

We applaud the EU for taking the initiative to reduce deforestation in its supply chains, and we urge the EU to consider the particularly high deforestation risk that Brazilian soy and beef carry, as well as the ready-to-go or nearly ready-to-go solutions for ensuring clean supply chains in Brazil.

COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply welcomes the Commission’s initiative aiming at minimising the risk of deforestation and forest degradation associated with products placed on the EU market.

Bayer welcomes the opportunity to contribute to the Commission’s “EU Action to Protect and Restore the World’s Forests” Impact Assessment Inception. Bayer supports the creation of deforestation-free supply chains by enabling the creation of sustainable resilient farming system.

“DAFC supports the EU-Commission’s objective to help counter deforestation, loss of biodiversity violations to human rights and greenhouse gas emissions. We realize that part of the soy production might take place in areas with non-negligible deforestation risk, placing soy as a forest risk commodity.

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AVEC (EU poultry meat sector) shares the EU-Commission’s objective to fight against deforestation, improve biodiversity, prevent violations to human rights and limit greenhouse gas emissions. As regards poultry meat, soy is an essential part of the feed ration, contributing to a balanced protein supply for the animals.

Please note that ACT Alliance Advocacy to the EU (ACTAlliance EU) is preparing a submission for the public consultation on the Farm to Fork strategy with a focus on the external dimension of Food Sustainability issues and policy coherence for sustainable development; looking at pros and cons of Voluntary Sustainability Standards.

Copa and Cogeca are the united voice of farmers and agri-cooperatives in the EU. Together we represent over 22 million farmers and their family members and the interests of 22.000 agri-cooperatives. Copa and Cogeca understand the importance of the problems that European Commission is trying to tackle with this initiative.

Copa and Cogeca are the united voice of farmers and agri-cooperatives in the EU. Together we represent over 22 million farmers and their family members and the interests of 22.000 agri-cooperatives. Copa and Cogeca understand the importance of the problems that European Commission is trying to tackle with this initiative.

The State Forests National Forest Holding is a Polish governmental organization that manages state-owned Polish forests on behalf of the Polish State Treasury. It was founded in 1924 and now oversees about 7.5 million hectares of forests (about 77% of Polish forests and 25% of Poland's territory).

IEEP welcomes the Roadmap as an acknowledgement that the European Commission needs to address deforestation and forest degradation through legislative measures. We also welcome the recognition that the EU is a major importer of agricultural commodities and therefore part of the problem, but also part of the solution to reduce global deforestation.

Henkel welcomes the announcement of the European Commission to present an integrated initiative for increasing the coherence of EU policies and voluntary principles to help better implementing actions tackling global deforestation and forest degradation in a holistic way.

Global Canopy welcomes the Inception Impact Assessment’s recognition of the need to address Europe’s deforestation footprint linked to commodity imports. Agricultural expansion is a major driver of deforestation, with serious consequences for the climate and for biodiversity.

T&E wishes to provide feedback on this initiative on to avoid deforestation associated with products placed in the EU. Please refer to the document in attachment for a full background note as a basis for our feedback. We welcome and appreciate the efforts of the EU in terms of deforestation to try and reduce the EU’s impact in forests.

Environmental Investigation Agency’s contribution to the Public consultation on the Roadmap "Minimising the risk of deforestation and forest degradation associated with products placed on the EU market" EIA welcomes the Roadmap proposed by the Commission and the planned impact assessment of regulatory measures to minimise the risk that products produced with deforestation and degradation are placed on the EU market.

CDP Europe is part of the global CDP non-profit network, that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$96 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental…

Feedback on the interception Impact Assessment on “Minimising the risk of deforestation and forest degradation associated with products placed on the EU market” The Swedish Society for Nature Conservation welcomes the commitment of the Commission to step up EU action to protect and restore the world’s forests.

WCS EU welcomes this opportunity to provide feedback on the EU Roadmap regarding ‘Minimising the risk of deforestation and forest degradation associated with products placed on the EU market’. WCS EU is a Belgian NGO affiliated with the Wildlife Conservation Society (WCS), a global NGO working to deliver wildlife conservation programmes in over 60 countries, mainly in Africa, Asia, the Pacific and Latin America.

Tropenbos International welcomes the commitment of the Commission to step up EU action to protect and restore the world’s forests. For the EU to substantially reduce the contribution to global deforestation and to fulfil their international commitments such as under the Paris climate targets, Convention on Biological Diversity and the Sustainable Development Goals, ambitious intervention measures are needed.

ClientEarth welcomes the Roadmap and the commitment of the Commission to carry out an impact assessment of regulatory and non-regulatory options for additional demand-side measures to minimise the risk that products linked to deforestation are placed on the EU market. ClientEarth invites the Commission to promptly adopt robust regulatory measures.

In line with the above cited literature about sustainability standards in general, it is very concerning the current emphasis of the EU on private certifications and the wide divergence found between private certificates ensuring deforestation-free meat supply-chains and other independent assessments.

The Confederation of European Forest Owners (CEPF) has welcomed the European Commission’s Communication aiming at addressing global deforestation published in July 2019. European Forest Owners support the EU in taking actions to tackle this issue.

We share the objectives of the European Commission to minimise the EU’s contribution to deforestation and forest degradation worldwide and promote the consumption of products from deforestation-free supply chains in the EU.

The EU’s goal should be to ensure an overall reduction of deforestation on the ground rather than only allowing clean supply chains to place products on the EU market, which does not solve the problem of deforestation. A more effective, long-term, and constructive approach is one that helps the entire agricultural sector (sustainable and unsustainable) move towards sustainability.

The Malaysian Palm Oil Council (MPOC) represents the interests of the Malaysian palm oil producers, exporters, end users and consumers worldwide. MPOC looks with interest and cooperative spirit to the EU’s legislative initiative on “Minimising the risk of deforestation and forest degradation associated with products placed on the EU market”, hoping that the consultative process ahead will ensure that the legislative…

• The EC should use their leverage in a positive manner and use the option of Regulatory Measures to promote sustainable production. So to make a real difference on the ground and not to use the measures to create more administrative burdens and to hamper international trade; • Regulatory measures should not be used as a protective measure to decrease the import of SPO in the EU – in contrary – the regulatory…

The Round Table on Responsible Soy Association (RTRS) welcomes the European Commission’s efforts in seeking proportionate and targeted actions to reduce the impacts of products imported into the EU that are associated with deforestation. As such, RTRS is committed to reducing the negative environmental and social consequences of the production and use of forest-risk commodities such as soy.

The Rainforest Alliance welcomes the opportunity to give feedback on the roadmap on ‘Deforestation and forest degradation – reducing the impact of products placed on the EU market’. The work of the Rainforest Alliance is based on the voluntary commitment to sustainability of our partners throughout the supply chain.

EDA welcomes the initiative aimed at minimising the EU’s contribution to deforestation and forest degradation worldwide, promoting the consumption of products from deforestation-free supply chains. The European dairy sector is aware of its impact beyond EU borders, even if often smaller per litre of milk than the impact of overseas production.

Solidaridad Network Input Public Consultation on Stepping up EU Action against Deforestation 3 March 2020 Solidaridad Network highly welcomes the EU initiative to step up EU Action against Deforestation and Forest Degradation.

Ajinomoto Animal Nutrition Europe (AANE) would like to thank the European Commission for the opportunity to participate in the consultation. The option proposed by AANE tackles the deforestation associated with EU feed and livestock industry. It is possible to reduce the crude protein content of feed diets, while maintaining animal performance with amino acids supplementation.

UECBV supports the EU-Commission’s objective to help counter deforestation, loss of biodiversity violations to human rights and greenhouse gas emissions. We realize that part of the soy production might take place in areas with non-negligible deforestation risk, placing soy as a forest risk commodity.

Global Witness welcomes the European Commission’s roadmap and commitment to carry out an impact assessment of regulatory and non-regulatory options for additional demand side measures to minimize the risk that products linked to deforestation are placed on the EU market.

FoodDrinkEurope welcomes the Commission's roadmap/Inception impact assessment on 'Minimising the risk of deforestation and forest degradation associated with products placed on the EU market’ as an integral part of the EU Green Deal mainstreaming biodiversity and resource efficiency with climate objectives, thus contributing to the implementation of the UN 2030 Agenda for Sustainable Development (SDGs), alongside…

Farm Europe welcomes this consultation and would like to give the following feedback to the initiative: Due to their importance to the Earth’s ecosystem, forests and especially rainforests like the Amazon, Borneo or the Congo Basin are a universal common good and concern of all humanity and should be preserved.

FEFAC is the European Feed Manufacturers' Association. FEFAC acknowledges the importance of ensuring that the EU helps to counter biodiversity loss, deforestation and any violation of human rights. Soy is a forest risk commodity that can contribute to these issues and the European soy supply chain carries a responsibility to take action where it can.

CAOBISCO members are committed to ensuring that their products are manufactured responsibly and to the highest standards, minimising environmental impact and respecting the human rights of those in their value chains.

Finnish Forest industries Federation welcomes the European Commission efforts in seeking proportionate and targeted actions to reduce the impacts of products that are imported to the EU and that are associated with deforestation.

EPOA (The European Palm Oil Alliance) fully underlines the need to fight biodiversity loss and climate change. We agree with the need to move towards sustainable and deforestation-free supply chains for the EU market. EPOA supports the development, initiatives and concrete measures to produce, trade and consume deforestation-free palm oil.

The EU and UN cannot meet their climate goals unless they step up action to protect the world’s forests. The first way to do this is by strengthening forest and land governance. As numerous studies have proven, forests are protected best when land and tree tenure rights of local communities are legally recognized.

Forest Peoples Programme (FPP) welcomes the commitment of the Commission to step up EU action to protect and restore the world’s forests. There are five key points that FPP would like to raise in relation to the proposed inception impact assessment.

WWF EPO comments on roadmap: The 5 year assessment report of the New York Declaration on forests states that an area of tree cover size of the United Kingdom was lost every year between 2014-2018, with new hotspots emerging in Africa and highest losses still in Latin America: the average annual tree cover loss in the tropics between 2014 and 2018 led to 4.7 gigatons of emitted carbon – more than the whole of the EU…

As a family forest owners, we welcome EU initiatives to strengthen EU action to combat deforestation and forest degradation. We would like to recall that EU forests are managed in accordance with the principles of sustainable forest management and that EU forests have grown steadily and productivity has increased over the last decades.

Conservation International (CI) welcomes the inception impact assessment of regulatory and non-regulatory options for additional demand side measures to minimize the risk that products linked to deforestation are placed on the EU market and to develop a definition of deforestation-free supply chains.

A/We welcome the recognition that the expansion of agriculture is one of the main drivers of deforestation and the role of EU trade is clearly recognised. However, we are disappointed that despite this recognition in the problem definition, there is no clear recognition of the need to reduce the EU demand for agro-commodities. This will open the EU initiatives for justified criticism.

Filed in Dutch · English published by the European Commission

As a major importer of agricultural and timber products, the EU should lead the way and step up efforts to combat global deforestation and forest degradation. Thus, Denmark strongly welcomes the European Commission’s focus on the issue and looks forward to the impact assessment as a follow-up to the Commission’s long-awaited communication from July 2019 on stepping up EU action to protect and restore the world’s…

FEDIOL is the association representing the EU vegetable oil and protein meal industry. Companies in our sectors acknowledge the responsibility they have for the sustainable production of commodities which they trade or process.

A/ We welcome the acknowledgement that the expansion of agriculture is one of the most important drivers of deforestation and the role of the EU's trade in this is clearly recognised. We are however disappointed that despite this recognition, clear acknowledgement of the need to cut the EU’s demand for agrocommodities is missing from the problem definition.

The beverage carton industry strongly supports the use of due diligence systems for operators placing timber and timber products on the European market, together with a robust traceability system for operators along the supply chain. These due diligence and traceability systems help prevent the risk of illegally harvested timber and timber products entering the EU.

IDH welcomes the initiative and supports the ongoing work relating to halting deforestation. We would like to share several thoughts in our response. 1. We recently published an overarching report on deforestation relating to agriculture, summarizing much of the available insights, with 9 recommendations for next steps: 1. Adopt mandatory reporting guidelines and due diligence 2.

Greenpeace European Unit welcomes this consultation and would like to share the following remarks: - The clear lesson learned after a decade of pledges to clean up the supply chains of commodities like meat, palm oil, timber and soy fed to animals from forest destruction is that industry self-regulation initiatives have failed to deliver.

European paper and board industry welcomes the European Commission efforts in seeking proportionate and targeted actions to reduce the impacts of products that are imported to the EU and that are associated with deforestation.

We strongly welcome the EU's next steps in minimising risks on deforestation and forest degradation. As such, the VOICE Network - an umbrella organisation of the major NGOs and Trade Unions involved in the cocoa sector - have been involved in drafting a request for an EU regulation on due diligence on both forest protection and human rights - as these go hand in hand.

ICMSA is a farm organisation that represents the interests of dairy and livestock farmers in Ireland. In response to the roadmap “Minimising the risk of deforestation and forest degradation associated with products placed on the EU market”, ICMSA would like to highlight the contradiction in EU policy where the EU states its intention to protect forests while at the same time allows the importation of food from…

Zero Land Degradation, Deforestation, Desertification could be achived if Vertical Multifloor Farming (V-Farming) , similar to the Aerofarms (aerofarms.com) Intelligent-Farming Technology is being introduced. Aerofarms has already built and runs successfully nine V-Farms of that type in New Jersey, USA.

Green or otherwise generally plants help to keep the concentration of carbon dioxide in the atmosphere stable. The use of fossil fuels and the forest are causing an increase of CO2 in the atmosphere, which has direct influence in phenomena such as the greenhouse effect and global warming.

Filed in Italian · English published by the European Commission

Dear European Commission, Dear Lady/Sir, After reading the Roadmap for Minimizing the Risk of Deforestation and Forest Degradation Associated with Products on the EU Market, The following are my suggestions below for achieving your goals. Applicable field: Economics / Environment - economics. Therefore, risk and related concepts are also applicable in the context of environmental economics.

The Commission might want to consider in the assessment of impacts also secondary positive impacts in Europe. Potentially higher prices for imported goods might make products produced in Europe more compatible: e.g. animal feed produced from European protein plants, food ingredients produced from European legumes, meat from livestock raised on European permanent grassland.