Introduction We thank you for the opportunity to offer input on the Roadmap towards a Communication on Stepping Up EU Action against Deforestation and Forest Degradation. Mighty Earth welcomes an integrated European Union approach to combat the deforestation, forest degradation, peatland destruction, forest burning, exploitation of people, and egregious human rights abuses that currently characterize many EU supply…
EU consultation
Stepping up EU Action against Deforestation and Forest Degradation
60 submissions from 58 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 1,156 submissions on this file. Shown here: the 60 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
16 submissions from industry — companies and their trade associations — against 34 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
- 16 of 58
- in the EU Register
- 105
- full-time lobbying staff
- €1.8M+
- declared costs a year
- 84
- EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 25 Feb 2019 — it ran from 14 Jan 2019.
- Policy area
- Sustainability (DG ENV)
- Where it stands
- Awaiting adoption
How it got here
- Roadmap15 Jan 2019
- Public consultation25 Feb 2019
Showing 25 of 60 submissions.
Greenpeace
· · filed 15 Jan 2019 · source
Hello, I believe it is important and urgent for the European Commission to take a firm stance against the deforestation of primary forests by multinationals and to propose penalties for the damage done. This is important for at least 3 reasons: > safeguarding biodiversity > global warming > protection of scented populations Best regards
Filed in French · English published by the European Commission
Nature and Youth Sweden
· · filed 15 Jan 2019 · source
We, Nature and Youth Sweden, welcome this initiative. Our organization has over seventy years of experience in environmental issues associated with deforestation and forest degradation. We see that, time after time, companies’ desire to make profit triumphs over environmental rights with the consequences being loss of biodiversity and increasing numbers of endangered species.
The Royal Society for the Protection of Birds
· · filed 15 Jan 2019 · source
Protecting forests, and other carbon- and biodiversity- rich land presents a huge opportunity to deliver climate change mitigation and reduce biodiversity loss, which in turn delivers a host of critical ecosystem services that range from local benefits: pollination, local climate regulation (temperature, wind, humidity), healthy soils, to regional and global benefits, including reduced and avoided emissions…
Reseau des Organisations de la Société Civile pour le Développement du Tonkpi (ROSCIDET)
· · filed 15 Jan 2019 · source
Good morning Dear Tout.te.s, I share with you the contribution of the Civil Society Organisations Network for the Development of Tonkpi (ROSCDET) www.roscidet.com. It is a network of Ivorian NGOs specialising in research and development of environmental solutions, the green economy, finance for the fight against change. climate, sustainable development. The 2063 EU Agenda African.
Filed in French · English published by the European Commission
Rainforest Alliance
· · filed 15 Jan 2019 · source
The Rainforest Alliance welcomes the European Union (EU) communication on stepping up EU Action against Deforestation and Forest Degradation as increased commitment to action in the fight against deforestation and forest degradation. We believe that EU support will bring essential added value, especially in installing demand-side measures and providing supply-side support.
University of Padova/ TESAF Department
· · filed 15 Jan 2019 · source
As a University department with more than 20 years of experience in different aspects of forest management and conservation we are happy to finally see attempts to assume responsibilities and to reduce negative impacts on important ecosystems and forest lands located outside of EU.
Forest Stewardship Council A.C.
· · filed 15 Jan 2019 · source
I respond on behalf of FSC, the Forest Stewardship Council. FSC welcomes the decision of the Commission to develop an action plan focussing on both forest degradation and deforestation, which together, in particular in the tropics, are important sources of biodiversity loss and climate change.
ESPOAG Feedback to the European Commission Roadmap “Deforestation and forest degradation – stepping up EU action” The European Sustainable Palm Oil Advocacy Group (ESPOAG) representing EU food sectors is committed to supporting the EU to stop deforestation and to support the promotion of this objective at the international level.
INKOTA (www.inkota.de) is a development organization in Germany. We are working on human rights in global value chains and on global agriculture and food security. The following feedback is specifically with regards to developments in the cocoa sector. INKOTA welcomes the initiative of the European Commission to set up a roadmap on deforestation and forest degradation.
ECA members have been closely following developments at EU level to consider policy options in line with the EU forest strategy to end deforestation and forest degradation. Therefore, ECA members welcome the EU suggested coherent and comprehensive approach and notably the proposed support to existing commitments by governments and the private sector.
Solidaridad Network
· · filed 15 Jan 2019 · source
Solidaridad Network welcomes the publication of the roadmap for a Communication on stepping up EU Action against Deforestation and Forest Degradation. We value the aim to increase the coherence of existing EU policies and voluntary principles, and help better implement actions that are already undertaken by governments and by the private sector to reduce global deforestation.
The World Fair Trade Organization Europe welcomes the European Commission’s initiative on mitigating deforestation and forest degradation and current models of production and trade of Forest Risk Agricultural Commodities (FRAC) many of which are unsustainable and already identified as main causes of deforestation.
EPOA -The European Palm Oil Alliance
· · filed 15 Jan 2019 · source
EPOA (The European Palm Oil Alliance) acknowledges the importance of this publication aiming to tackle the problem of deforestation and forest degradation including international action at public and private level. EPOA believes that the protection of rainforest is only possible when we cooperate with each other and empower those companies that make sustainable palm oil a reality.
BASP – Belgian Alliance for Sustainable Palm Oil – started its activities in 2012 and now has 16 members, including companies and industry associations. Their common goal is to increase awareness about sustainable palm oil, by setting the example and monitoring the progress made in their respective sectors.
VOICE Network (The Umbrella Association of Civil Society Organisations in Cocoa)
· · filed 15 Jan 2019 · source
This feedback is specifically aimed at the cocoa component of the EU Action Plan. Voluntary corporate social responsibility initiatives by companies alone cannot prevent human rights violations and environmental degradation. In consuming nations, there is no legal threshold for sustainability.
Natural Resources Defense Council (NRDC)
· · filed 15 Jan 2019 · source
NRDC welcomes the EU’s initiative to tackle global deforestation and forest degradation. The world must take urgent action to halt the devastation of the world’s forest, which are vital for biodiversity, and are our best tool for removing heat-trapping carbon dioxide from the atmosphere. The roadmap correctly identifies the expansion of agriculture as one key driver of global deforestation and forest degradation.
World Resources Institute
· · filed 15 Jan 2019 · source
The World Resources Institute welcomes the introduction of a roadmap to step-up EU action against deforestation. The roadmap should not be limited to current regulations and include consideration of new regulations on trade in products linked to deforestation. This could be modelled broadly on the EU timber regulation and related EU FLEGT Action Plan.
Volt France
· · filed 15 Jan 2019 · source
Volt France opinion We welcome the European Commission’s proposal to address problems related to deforestation and forest degradation. We also support the proposed measures, which in our view are aimed at creating more transparency and cooperation between stakeholders in the forest industry sector.
Filed in French · English published by the European Commission
Various studies have shown the particular responsibility the EU has when it comes to countering this deforestation crisis. In the cocoa sector, for example, more than 60% of global cocoa goes through the EU. Therefore, the EU really holds a key position to push for change in this sector.
A coherent EU forest Action Plan is long overdue. It must include binding legislative measures and ensure that other EU Directives and decisions do not undermine the aims of halting deforestation and biodiversity loss by 2020, as set out in the Sustainable Development Goals and the Convention on Biological Diversity (CBD) Aichi Targets.
Global Witness
· · filed 15 Jan 2019 · source
Global Witness welcomes the road map and plans to publish a communication on stepping up EU Action Against Deforestation and Forest Degradation. However, we are concerned that the road map indicates that the long-awaited communication may not include the measures needed to make a difference as it appears to rule out new legislation and is limited to setting out a “framework for existing policies and tools”.
Forest Trends welcomes the Roadmap as an acknowledgement that the Commission desires to amplify its action to address deforestation and forest degradation. However, we are concerned that the framework relies solely on increasing the coherence of existing EU policies and tools, existing commitments by governments and the private sector, and actions already undertaken by the EU and Member States.
The European Tyre & Rubber Manufacturers Association (ETRMA) and its members are fully committed to ensure sustainable production and supply of natural rubber. This means looking after the people, communities and natural resources touched by natural rubber production and supply. Therefore, ETRMA supports the Commission’s Deforestation Roadmap initiative.
Bayerischer Jagdverband
· · filed 15 Jan 2019 · source
The Bavarian Hunting Association as a recognised nature conservation association regularly assesses the development of Bavarian forests. For a long time, the area of forests in Bavaria has not decreased but, on the contrary, is on the rise. The Bavarian forestry administration also agrees with this statement.
Filed in German · English published by the European Commission
The growing European demand of biofuel crops increase the need of agricultural land, converting valuable habitats and displacing other crops, with serious impacts on food security and significant greenhouse gas emissions from land use change as a result.
Both ENDS jointly with Forest Peoples Programme, FECONAU, FAPI, SESDev, SDI, Pusaka, & OKANI
· · filed 15 Jan 2019 · source
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. 1. NECESSITY AND MANDATE FOR LEGISLATIVE MEASURES 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…
ECA members have been closely following developments at EU level to consider policy options in line with the EU forest strategy to end deforestation and forest degradation. Therefore, ECA members welcome the EU suggested coherent and comprehensive approach and notably the proposed support to existing commitments by governments and the private sector.
Global deforestation needs to be halted if we are to win the fight against climate change, and the EU needs to lead by example. It is good the EU acknowledges its consumption is a part of the deforestation problem and that stepping up action is needed. The overall objective of the roadmap is hence welcome. The EU cannot afford any more false solutions in the name of climate change.
Ajinomoto Animal Nutrition Europe
· · filed 15 Jan 2019 · source
Ajinomoto Animal Nutrition Europe (AANE) is an amino-acid producing company, with production facilities located in Amiens, France. AANE is a leading company regarding the production and the development of feed-use amino-acids.
Government of Colombia
· · filed 15 Jan 2019 · source
For Colombia, THE FIGHT AGAINST DEFORESTATION IS A STATE PRIORITY. We are conscious of the challenges we face being the 2nd most biodiverse country in the world and the 3rd most forested country in South America. As such, Colombia has not only lead the international reflections that resulted in the SDGs, but has also incorporated them into its internal agenda with a multidimensional focus.
Fern welcomes the initiative of a Roadmap but we are concerned about the suggested reliance on existing policies and tools to step up EU action, as the Roadmap does not expressly recommend filling gaps in the existing framework with new and targeted policy actions / new regulatory measures to contribute to halting, preventing and reversing deforestation.
ROBIN WOOD
· · filed 15 Jan 2019 · source
Robin WOOD welcomes the Commission’s roadmap, but we are also very concerned about whether it will also deliver the necessary legal regulations and remove existing gaps and shortcomings in order to really stop/prevent FRACs deforestation.
Filed in German · English published by the European Commission
Fair Trade Advocacy Office
· · filed 15 Jan 2019 · source
We very much welcome the European Commission’s initiative to tackle the deforestation issue, and the related unsustainable production and trade of forest risk commodities. With regards to the problem analysis, we agree that the drivers of deforestation and forest degradation are complex and multiple. We would like to highlight poverty as one of the major factors.
Ecosia - the search engine that plants trees
· · filed 15 Jan 2019 · source
We very much welcome this initiative and believe that the European Union can have a fast and drastic impact on global deforestation if it focuses on what matters most and on what it can impact directly. In this regard, we have three concrete suggestions. According to a 2013 technical report from the European Commission, the EU is the world‘s largest net importer of deforestation.
Ministry of Environment and Food of Denmark
· · filed 15 Jan 2019 · source
The Ministry of Environment and Food of Denmark welcomes the Commission’s launch of a roadmap for the development of a communication on stepping up EU Action against Deforestation and Forest Degradation. We recommend that the Communication includes an ambitious EU Action Plan on Deforestation and Forest Degradation as already called and urged for from many sides.
WWF European Policy Office
· · filed 15 Jan 2019 · source
WWF welcomes the European Commission’s initiative to step up EU action against deforestation and forest degradation as expressed in the roadmap, following numerous calls by NGOs, civil society organisations and clear demands by the European Parliament and EU Member States. Nevertheless, we are of the opinion that the measures proposed in the roadmap will not live up to the challenge.
The tropics has favourable climatic and soil conditions which are ideal for plant growth. These conditions are reflected with the existence of tropical forests which are luxuriant in growth and of high biodiversity. Because of the favourable conditions, cleared land quickly reverts back to vegetation if left in situ.
IPPA Nigeria - Palm Oil Farmers Unite!
· · filed 14 Jan 2019 · source
The EU Roadmap is the latest initiative from the Commission to discriminate against palm oil. This Roadmap is part of the wider campaign against palm oil, following the proposal by the EU Parliament to ban palm oil biofuels via the Renewable Energy Directive (RED) and the ongoing discussion within the Commission on a “Deforestation Criteria”, aimed at depicting palm oil as “risky”.
National Association of SmallHolders (NASH)
· · filed 14 Jan 2019 · source
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.
Matilija University
· · filed 14 Jan 2019 · source
Draft Response to the European Union, composed last night for the XR Amazonia Solidarity group: For the Peoples of Amazonia, Witness that in 2019: 90-95 Percent or more of our Wild Vertebrate Biomass has been Eradicated: 90-95 Percent or more of our Rivers, Biodiverse Forests & Rainforests, and our once living Oceans, Destroyed.
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.
Alliance pour la Préservation des Forêts
· · filed 14 Jan 2019 · source
We are a group of responsible industrialists and distributors decided to stop deforestation imported to Europe via our supply chains and associated social exclusions. We welcome this EU initiative to combat deforestation and support an ambitious and coherent approach with the UN SDGs and the recent report by the Intergovernmental Panel on Climate Change.
Filed in French · English published by the European Commission
International Cocoa Organization
· · filed 14 Jan 2019 · source
The International Cocoa Organization (ICCO) and its Member countries are aware that agriculture is one of the biggest drivers of deforestation and share the concerns about the impacts of cocoa farming on existing forest areas, as it was affirmed in the Berlin Declaration in April 2018 (point 11: https://www.icco.org/about-us/icco-news/387-berlin-declaration-of-the-fourth-world-cocoa-conference.html).
The Roundtable on Sustainable Palm Oil (RSPO) supports the European Commission’s commitment to tackling deforestation and forest degradation. To limit unsustainable palm oil-related deforestation, RSPO recommends making sustainable palm oil the norm by promoting stricter certification standards, sector-wide transparency, encouraging consumers to choose sustainable products, engaging with producer countries and…
Birdlife Europe
· · filed 14 Jan 2019 · source
BirdLife welcomes this vital initiative. Urgent EU action is essential to help keep natural and intact forests standing if global biodiversity objectives, Sustainable Development Goals and the Paris Agreement are to be met. The EU has a global responsibility to play a leadership role as one of the primary markets for forest commodities. BirdLife has the following comments: 1.
FEDIOL - EU Vegetable Oil and Proteinmeal Industry
· · filed 14 Jan 2019 · source
FEDIOL, representing the EU Vegetable Oil and Proteinmeal Industry, welcomes the publication of the roadmap for a Communication on stepping up EU Action against Deforestation and Forest Degradation. As underlined, the Communication should aim at increasing the coherence of existing EU policies and help better implement actions that are already undertaken as well as existing commitments by governments and by the…
Feedback on the Commission’s roadmap ‘on stepping up EU Action against Deforestation and Forest Degradation’ ePURE, the association representing European producers of renewable ethanol from conventional and advanced feedstock, welcomes the European Commission’s initiative to step up EU Action against Deforestation and Forest Degradation.
Tropenbos International recommends that the EU develops an ambitious action plan to step up against deforestation. Given the current rates of deforestation despite numerous initiatives, we conclude that voluntary efforts are progressing too slowly and that a next step should be taken to regulate EU imports of agricultural goods.
Conservation International
· · filed 11 Jan 2019 · source
Conservation International (CI) welcomes the Roadmap that announces a communication on stepping up EU action on deforestation and forest degradation. CI also welcomes the recognition of the impact of EU consumption of agricultural commodities on forests in the world and the associated leverage to act.
ClientEarth welcomes the Roadmap as an acknowledgement that the Commission needs to amplify its action to address deforestation and forest degradation. However, we are concerned about the proposed reliance on existing policies and tools to step up EU action, as the Roadmap does not expressly recommend filling gaps in the existing framework with new and targeted policy actions / new regulatory measures.
Nature and Youth sweden
· · filed 11 Jan 2019 · source
Cutting down old forest that contain high diversity of organism is something that will cause extinction of many species. This kind of acitivity is something that is taking place right now all over the world, Sweden is one of the countries. We have to protect these forests from forestry because the existing laws is not enough.
FEFAC shares the importance that is attributed to tackling deforestation and forest degradation as well as to stimulating agricultural commodity chains that take into account sustainable production. FEFAC has been engaged on the topic of responsible soy since 2006.
APPA Biocarburantes
· · filed 11 Jan 2019 · source
As shown by the roadmap presented by the European Commission, the EU has been looking for more than ten years on the issue of deforestation at global level through various Communications, Strategies and Programmes. In parallel, some regulatory initiatives have been launched in recent years which highlight the FLEGT Action Plan in relation to trade in timber.
Filed in Spanish · English published by the European Commission
Communication on stepping up EU Action against Deforestation and Forest Degradation Roadmap feedback by the Swedish Forest Industries Federation (SFIF) A1. Problem the initiative aims to tackle SFIF agrees that the drivers are multiple and complex as described in the roadmap. Many initiatives have been taken in the past (TFAP.
In this action plan, the central cause of deforestation in tropical regions is not sufficiently precise addressed. Accordingly effective actions are missing. Problem definition The fertility of soils in tropical regions is rapidly decreasing as they are converted from forest to agricultural land. This is due to increased microbiological activity, leaching of nutrients and erosion of the soil substance.
Nova Scotia has the most intensively harvested forests in Canada on some of the most nutrient poor soils. For over 100 years, pulp and paper production has driven degradation of our forests, with massive loss of Old Growth, now less than 0.5% of the landscape, down from circa 15 % in the 1950s and 50% of more in pre-European times.
Climate science on the importance of preserving and protecting as many forests and copses as possible comes out almost every week. Forests are carbon capture zones, no longer commodities to be traded away. Wood Biomass energy should not be included in the list of renewable energy.
University of York Gardening Society
· · filed 3 Jan 2019 · source
We need an effective Carbon Tax to stop environmental destruction. We also need more focus not only on stopping deforestation but also huge reforestation projects! These are not given significant enough attention.
The initiative is extremely relevant to fight climate change and to preserve biodiversity – good initiative! Try to make even more concrete initiatives; to create economic drivers to avoid deforestation due to the demand for biofuels, and to avoid monocultures due to agricultural needs. Try to emphasize good examples of international, bilateral or EU-development agreements, that would/could show a way forward.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.