Weakening the EU deforestation regulation (EUDR) by including it in plans to "simplify" environmental legislation will undermine business confidence, increase costs and damage progress towards goals on climate change, biodiversity loss and food security, according to Trase’s submission to a consultation by the European Commission.
Trase data and intelligence has been used by the European Commission, member state governments, enforcement agencies, politicians and civil society groups in the creation of the EU deforestation regulation – the first-ever legislation aimed at breaking the link between deforestation and the trade in agricultural commodities.
Existing publicly available geospatial data can help companies and competent authorities meet the requirements of the EU deforestation regulation, according to a report by Trase commissioned by ClientEarth. But it is important that they are aware of how best to use it.
Tony’s Chocolonely’s ‘open chain’ initiative offers a best-practice example of how companies could engage with their suppliers in a way that protects and supports the livelihoods of smallholder farmers while also ensuring compliance with the EU deforestation regulation (EUDR).
Trase outlines its recommendations to make the best use of the one-year delay in the implementation of the EU deforestation regulation (EUDR) to further develop the guidance, partnerships and finance needed to achieve a successful transition to deforestation-free commodity supply chains.
Amendments to the EU deforestation regulations proposed by the EPP group in the European Parliament are not based on evidence and could breach free-trade rules.
Trase research shows huge variations in the traceability of cocoa from Côte d’Ivoire and the likelihood of whether supplies will comply with the EU deforestation regulation. Support for smallholder farmers is needed to avoid excluding them from the EU market, as companies prepare for regulation.
Helen Bellfield and Toby Gardner, Trase’s co-directors, answer some frequently asked questions about the benefits and limitations of our data in assisting companies and governments in their efforts to implement the EU deforestation regulation (EUDR).
EU imports of agricultural commodities continue to drive substantial global deforestation with cocoa and oil palm being the main culprits, new Trase research shows. Our analysis reveals striking differences between countries in deforestation exposure and the products responsible as they prepare to implement the regulation on deforestation-free products (EUDR).
Human rights and environmental due diligence can clean-up specific commodity supply chains, but to ensure that products linked to deforestation are not redirected elsewhere, governments need to build synergies with other policies for sustainable land use.
Traders will struggle to prove that soy from Brazil complies with its environmental laws due to gaps in official data, potentially reducing sales to the EU, according to a report by Trase and Instituto Centro de Vida (ICV).
Trase and Proforest have published recommendations for establishing a fair and effective risk benchmarking to underpin the EU deforestation regulation.
Many businesses are seeking clarity on how the EU deforestation regulation will be implemented, especially its proposed classification of countries by risk levels. The success of the law can be boosted by the EU closely engaging producing countries and using the best available deforestation data - including zooming in on regions within countries when considering risk.
A narrow focus on protecting forests could increase pressure on other ecosystems in South America where most of the EU’s commodity-driven deforestation exposure is found.
Implementation of the draft regulation could be improved by using robust risk assessment to target action on areas threatened most by deforestation.
Trase analysis of the EU’s draft due diligence regulation finds that the proposal fails to account for more than half of the bloc’s deforestation risk from imports of soy due to its exclusion of soy used in animal feed.
Trase research is an important part of a new WWF report into tropical deforestation associated with EU agricultural commodity imports.
Weakening the EU deforestation regulation (EUDR) by including it in plans to "simplify" environmental legislation will undermine business confidence, increase costs and damage progress towards goals on climate change, biodiversity loss and food security, according to Trase’s submission to a consultation by the European Commission.
Trase data and intelligence has been used by the European Commission, member state governments, enforcement agencies, politicians and civil society groups in the creation of the EU deforestation regulation – the first-ever legislation aimed at breaking the link between deforestation and the trade in agricultural commodities.
Existing publicly available geospatial data can help companies and competent authorities meet the requirements of the EU deforestation regulation, according to a report by Trase commissioned by ClientEarth. But it is important that they are aware of how best to use it.
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Under the EUDR, competent authorities of EU member states need to develop risk-based plans to identify the checks on commodity imports that they will carry out. The regulation sets out the different risk criteria for non-compliance that they should use, and it allows them to use data from the EUDR’s Information System as well as other relevant sources such as monitoring data, or risk profiles from international organisations. These risk criteria include aspects such as the complexity and length of the supply chain, the risk of mixing, and the presence of forests and deforestation. With budgets tight, using open data from multiple sources – even if not fully aligned with the EUDR – can play an important role in supporting a risk-based approach to enforcement that will increase the robustness of the regulation.
Trase is one such open dataset that can enable competent authorities to triage risk. This includes subnational risk benchmarking of commodity deforestation for risk profiling operators that supply EU member states and for risk profiling ports of export based on their likely sourcing patterns, as shown in Trase’s work for the French government. This information enables competent authorities to develop risk-based plans that can target shipments from higher risk operators, higher risk ports of export, and where plots of land are in high-risk subnational regions. Trase data shows that risks are often highly concentrated in a few production regions. Using subnational data can help target the relatively small percentage of checks on the highest risk products.
Reviews of the EUDR will include its possible extension beyond forests to other natural ecosystems, and the coverage of more products and new commodities. Trase data can be used to provide an important part of the evidence needed for these reviews. This includes data on the EU’s subnational sourcing patterns for key commodities and its exposure to conversion of different ecosystems. Trase data has already highlighted the EU’s exposure to the conversion of ‘other wooded land’ and native grasslands in South America, which are currently not covered by the EUDR. The new DeDuCE dataset developed at Chalmers University of Technology, a Trase science partner, can also support these crucially important reviews as it maps deforestation driven by the expansion of agriculture and forestry globally across all commodities and links these to trade and consumption by markets including the EU.
More broadly, these datasets are important inputs for analyses that will inform the EU’s first general review that will take place by June 2028, which encompasses an evaluation of the regulation’s impact on commodity deforestation, trade patterns, and farmers and smallholders. Trase’s systemic view of global trade will be critical to understanding the net effect of the regulation and any ‘leakage’ effects where deforestation shifts to other commodities, markets or ecosystems.
Companies need to provide the geolocation (as polygons or, in some specific cases, points) of the plots of land where commodities were produced. Trase data (with the exception of Indonesian pulp) maps subnational regions of production rather than individual farms or concessions, as this data is not publicly available at scale. Trase cannot therefore be used as a compliance tool to trace commodity production to plots of land under the EUDR.
Companies also need to demonstrate that the commodities they are selling or exporting to the EU have been sourced from plots of land which are compliant and have not been mixed with any commodities from non-compliant or unknown sources. This requires a sufficiently robust and credible traceability system that can ensure there is no risk of mixing or laundering.
While Trase maps the supply chain by bringing together lots of publicly available datasets, some of which are likely to be useful to evidence traceability such as cattle transit documents or supplier lists, Trase is not a traceability tool and does not map the individual transactions between producers, processors and traders.
Central to the due diligence process for operators and traders is to assess the risk that commodities being imported or sold in the EU do not comply with the requirement that they are deforestation-free and produced in accordance with the relevant legislation of the origin country. Only those assessed as posing no risk or only negligible risk can be placed on the market or exported.
The EUDR sets out fourteen criteria that should be included in the risk assessment. Trase can provide relevant information for criteria on “the prevalence of deforestation in the country of production or parts thereof”through its extensive data on subnational commodity deforestation. Although Trase’s definition of deforestation is not fully aligned with the EUDR (as we also include the conversion of other types of native vegetation where data is available), or with the end-of-2020 cut-off date, it can provide an excellent overview of subnational commodity deforestation exposure. This shows that deforestation is often highly concentrated in a minority of production regions, as is the case for Brazilian soy.
In some cases, Trase data can help companies understand at a high level the complexity of the relevant supply chain and the risks of mixing with non-compliant or unknown products (two other important risk criteria). For example, Trase data shows that 60% cocoa from the Côte d’Ivoire is indirectly sourced or of unknown origin. Work by Trase researchers has found similar issues across the soy, cattle, cocoa and palm oil supply chains.
Third parties are able to submit substantiated concerns to competent authorities about non-compliance of operators or traders, which the authorities are required to assess. Operators and traders who receive substantiated concerns should also investigate them and notify competent authorities where this information indicates that products already placed on the EU market are non-compliant.
While Trase data alone is unlikely to provide sufficient evidence of non-compliance as set out above, it can be used by civil society to identify high-risk shipments, ports, operators and sourcing regions where they can target investigations. This is especially the case in the absence of transparency on per-shipment import data by the EU and the lack of access for civil society to the EUDR Information System.
