Osvaldo Pereira

Vinícius Silgueiro

Ana Valdiones

Global market rules are now sharpening the focus on legal compliance alongside deforestation-free supply chains. Despite delays to its implementation, the EU Deforestation Regulation has led many companies to invest in 

 with its prohibition on commodities that were illegally produced or grown on deforested land. Meanwhile China, the largest buyer of Brazilian soy and beef, has begun piloting 

deforestation and conversion-free imports

, which points to a growing demand for legality-assured supply chains.

In Brazil, the Amazon and Cerrado biomes are threatened by the expansion of agricultural commodities. While the Brazilian 

 provides the legal framework for land use, verifying compliance at scale remains a challenge. An initial piece of evidence for compliance is the 

Authorisation for the Suppression of Vegetation (ASV)

, issued by environmental agencies to allow the removal and conversion of native vegetation. However, despite recent efforts aimed at increasing transparency and integrating data, information on these authorisations is often decentralised and difficult to access, creating a significant data gap. Without transparent, consolidated data on ASVs, it is difficult for buyers and regulators to know whether a specific area of deforestation was authorised or not.

 has published a systematic ASV database for Brazil. This initiative consolidates publicly available data on authorisations for native vegetation clearance making information more accessible for assessing legal compliance in regions impacted by deforestation in Brazil.

New analysis shows evidence of non-compliance

Trase is working with ICV to use this new database to bring further clarity on how consumer markets are exposed to unauthorised deforestation via imports of beef and soy from Brazil. In the first stage of this project, we compared official 

 for the period 2009–2024 with valid ASVs in order to estimate how much recent deforestation has taken place without an authorisation across the Amazon, Cerrado and Pantanal.

The results show a significant lack of public authorisations for the conversion of native vegetation. Across both the Amazon and Cerrado, deforestation totalled 26.4 million hectares (Mha) between 2009 and 2024. Of this total, 22.8 Mha (86%) lacked issued authorisations to clear native vegetation, while only 3.6 Mha (14%) overlapped areas with an ASV. This suggests that most of the deforestation in these biomes occurred without a recorded and publicly disclosed permit (see disclaimer at end).

In Brazil, most deforestation happens without authorisation

In the Amazon, the evidence of unauthorised deforestation is striking. Deforestation totalled 11.7 Mha during 2009–2024, with 11.2 Mha (96%) occurring without an ASV. Furthermore, the unauthorised deforestation is highly geographically concentrated. Just five municipalities accounted for 20% of all deforestation without an ASV. Three municipalities, Altamira, São Félix do Xingu and Porto Velho, accounted for 13% of the total unauthorised deforestation.

In the Cerrado, total deforestation reached 14.7 Mha in 2009–2024. While the proportion of unauthorised deforestation is lower than in the Amazon, the absolute area is high. We found that 11.7 Mha (78%) of deforestation occurred without an ASV, while only 3.2 Mha (22%) was covered by an authorisation. Deforestation without an ASV is less concentrated in the Cerrado compared to the Amazon. Our analysis shows that 29 municipalities accounted for 20% of the total deforested area without an ASV.

Enforcement less effective in the Cerrado

ICV’s database also includes information on 

 – sanctions issued by federal and state environmental agencies which serve as an additional indicator of environmental infractions. We compared official PRODES satellite deforestation data for the period 2009–2024 with Embargoed Areas to provide an extra layer of evidence of non-compliance.

Much of the deforestation in the Amazon is associated with Embargoed Areas

The analysis shows that 46% of all deforestation in the Amazon overlaps with Embargoed Areas, meaning that almost half of the unauthorised clearing has been flagged by federal enforcers.

In contrast, only 8% of deforestation in the Cerrado overlaps with embargoes. This discrepancy suggests that while non-compliance is widespread in both biomes, enforcement is far more active in the Amazon than in the Cerrado.

Enforcement is more active in the Amazon than the Cerrado

Managing risk in soy and beef supply chains

In the next stage of this project led by the Centre for Territorial Intelligence at the Federal University of Minas Gerais, we will focus on soy and beef production in the Cerrado, Amazon and Pantanal biomes, assessing compliance with the Forest Code and identifying cases linked to unauthorised deforestation using data on ASVs and Embargoed Areas.

This data will allow companies downstream in the supply chain that use soy and beef in their products to prioritise their due diligence and risk screening by identifying municipalities with the highest rates of unauthorised deforestation. For producer and consumer governments, it provides a roadmap for targeting enforcement and monitoring resources where they are most needed. Transparent data on legality is essential to strengthen accountability and support the transition to legal, deforestation-free supply chains.

Disclaimer: Despite Brazil's robust legal framework governing the transparency of environmental information, limitations exist in the completeness, format and accessibility of data on ASVs and Embargoed Areas. Consequently, caution should be exercised in the use and interpretation of the results of this analysis. Detailed information regarding the methodology of this analysis can be found 