Tell the EU to stand firm against deforestation!

Background of the EU Regulation

The European Parliament cites data from the Food and Agriculture Organization of the United Nations (FAO) as the reasons for the EU Deforestation Regulation (EUDR). It estimates that between 1990 and 2020, 420 million hectares of forest – an area larger than the European Union – were lost worldwide.

Every year, an additional 10 million hectares of forest are destroyed globally, 90 percent of which is caused by the expansion of cattle grazing and industrial farming areas.

However, the actual numbers are much higher: Many millions of hectares of forest are severely degraded every year by industrial logging and arson. Further forest areas are converted into industrial wood plantations such as eucalyptus monocultures. The FAO wrongly does not consider these actions to constitute forest loss.

In its legislation, the EU also takes into account the important role that forests play in the fight against climate change and the preservation of biodiversity. Forests store large quantities of carbon dioxide (CO₂) and are home to a large proportion of the world’s biodiversity. According to the EU, deforestation alone is responsible for 11 percent of global greenhouse gas emissions.

The products covered by the regulation and what companies need to do

The new regulation imposes business due diligence obligations on trade in timber, coffee, cocoa, rubber, palm oil, cattle and soy, as well as products derived from them, which are listed in Annex I to the regulation. They may only be imported, marketed in Europe, or exported if they are free from deforestation and do not damage forests. This means that the products may not have been produced on areas where forests have been cut down or degraded since December 31, 2020. The regulation applies to forests worldwide, including those in Europe.

In addition, the raw materials and products must be produced in compliance with the laws of the country of origin and with respect for human rights. The companies must confirm the fulfillment of their due diligence obligations and compliance with the regulation in a due diligence declaration. The regulation will apply to large and medium-sized companies from January 1, 2025, and will also come into force for small companies in the second half of the year.

Massive lobbying pressure from all sides

The situation of forests worldwide is dramatic, and urgent action must be taken to combat ongoing deforestation. But for months now, the European Commission has been inundated with requests from business and political interest groups demanding that the implementation of the regulation be postponed.

These include the European Confederation of Woodworking Industries, the EuroCommerce trade association, and a coalition of ten German industry associations. The Federation of German Industries (BDI) has strongly criticized the regulation and is calling for it to be dropped in a position paper.

The European People’s Party (EPP), which is made up of conservative member parties in the European Union, is calling for the regulation to be postponed. According to Euractiv, German MEP Peter Liese is leading the resistance against the impending implementation of the law, calling it a “bureaucratic monster”.

The agriculture ministers of 20 of the 27 EU member states, including Germany, Austria, France, Italy, Poland and Sweden, support proposals for revising the regulation and introducing it at a later date.

The German Minister of Agriculture, Cem Özdemir, is calling for the start of application of the regulation to be postponed until July 1, 2025. “Companies need sufficient time to prepare,” he said. From Rainforest Rescue’s perspective, this argument does not hold water, given that it has been deemed completely unacceptable for some time for European companies to purchase products linked to rainforest clearing or those produced in violation of local laws or human rights.

Countries such as Brazil, Canada, the United States, China, Australia, New Zealand, Indonesia and Malaysia have also spoken out against the EU regulation. Among other things, they argue that it is impossible for exporters to prepare adequately and that uncertainties remain.

Brazil’s government criticized the EU regulation as protectionist and threatened to file a lawsuit with the World Trade Organization (WTO).

The Indonesian government calls the EUDR discriminatory, fearing losses as the world’s largest palm oil producer. Indonesia’s Coordinating Minister for Economic Affairs even spoke of ‘regulatory imperialism’. At least 20 million hectares of rainforest have been cleared in the Southeast Asian country for oil palm plantations. Palm oil is one of Indonesia’s most important exports to the EU. Negotiations on the CEPA free trade agreement between the EU and Indonesia also seem to have stalled due to the EUDR.

From South America, the Southern Agricultural Council (CAS) – made up of the agriculture ministers of Brazil, Argentina, Bolivia, Paraguay, Chile and Uruguay with the objective of “coordinating regional measures” – is demanding carte blanche for further deforestation. The politicians criticize the attitude of European authorities, who in their opinion style themselves as “champions of environmental protection”.

Can South America continue to clear forest?

In most South American countries, deforestation rates remains alarmingly high. Yet CAS is trying to prevent the application of the EU regulation with flimsy arguments, claiming the legislation was “not scientifically sound”, and asserting that South American CAS member countries had “developed sustainable production systems”.

CAS refers particularly to soy supposedly grown sustainably, even though it remains one of the main drivers of deforestation in South America. In addition, it is almost exclusively genetically modified soy, the cultivation of which requires the spraying of vast amounts of herbicides and pesticides, a practice that is neither environmentally friendly nor socially acceptable.

Exporters and companies from outside the EU also cite technical concerns. As one of the foundations for the implementation of the regulation, the EU’s Joint Research Centre has created extensive databases with land use maps, satellite images, etc. and is relying on artificial intelligence. The companies question whether the analytical tools provided by the EU are sufficient or whether they could provide false information. Other concerns that have been raised relate to data protection.

To: the EU Commission, the EU Parliament, the EU Council of Ministers and the governments of the EU Member States

Ladies and Gentlemen,

10 million hectares of forests are cut down around the world every year. 90 percent of this is caused by the expansion of agricultural pasture and cropland.

The forests in large parts of South America are currently burning again because the agricultural industry is creating space for cattle and soy monocultures. 

Citizens in Europe, but also many people around the world, are calling for a stop to deforestation. They do not want to consume products for which forests are cleared and human rights are violated.

We therefore call on you to apply the new EU Regulation on deforestation-free products (EUDR) as decided from January 2025.

DO NOT give in to pressure from industry and trade interest groups or from governments in many countries demanding that the Regulation be watered down or its application delayed.

Yours faithfully,