New analysis shows EU could significantly cut deforestation footprint with a mix of policy tools

The EU Deforestation Regulation (EUDR) is the cornerstone of Europe’s response to global forest and biodiversity loss driven by its consumption of deforestation-linked commodities. It requires companies trading regulated commodities to ensure that products are deforestation-free and legally produced, helping to ‘de-risk’ EU supply chains from exposure to commodity-driven deforestation.

The new report, Expanding the toolkit: Exploring European policy pathways to reduce agricultural deforestation and biodiversity loss, compares how different policy pathways could reduce the EU27’s footprint linked to seven forest-risk commodities covered by the EUDR: cattle, cocoa, coffee, oil palm, rubber, soy and timber. The report is based on research by the Stockholm Environment Institute at the University of York and the Institute of Environmental Science at Leiden University, and supported by Sitra, the Finnish Innovation Fund.

The analysis starts by setting a modelled 2022 baseline for deforestation and associated greenhouse gas emissions and biodiversity footprints for the EU27, and then compares the results from a range of exploratory, but achievable, policy scenarios against this baseline.

The baseline footprint is not spread evenly. Cattle account for almost half of the EU’s total impact, and a relatively small number of EU member states and producer countries account for a large share of Europe’s overall footprint. This matters because it points to clear areas where policy action could have the greatest impact.

What de-risking Europe’s supply chain via the EUDR can achieve

The analysis uses consumption-based models and deforestation and biodiversity estimates from DeDuCE and the LIFE, respectively, to explore the implementation of EUDR-type action at three ambition levels. Modelled scenarios with lower ambition reflect implementation with a more limited scope and weaker enforcement by Competent Authorities, while higher ambition scenarios reflect broader scope and stronger enforcement (with medium ambition in between).

The results show that when EUDR-type measures are applied on their own, the EU’s modelled deforestation footprint falls by 21.7% under a lower ambition implementation, 32.4% under medium ambition and 68.2% under high ambition, compared with the baseline.

A central message is that successful implementation of the EUDR is key, even with lower ambition. This conclusion is especially relevant given that EUDR implementation has been delayed and discussions continue about whether and how aspects of the regulation may be simplified. The EUDR can have a large impact on the EU’s footprint, with stronger implementation levels that align with the original intent of the regulation leading to much larger footprint reductions than a more limited approach.

Broader policy tools can strengthen the impacts of the EUDR

The strongest footprint reductions from the scenario analysis come when EUDR-like measures are combined with additional policy levers that influence demand, domestic production and market incentives.

The measures explored are grouped into three broad areas which incentivise sustainable domestic consumption, sustainable production systems within the EU, and border adjustment mechanisms which place costs on unsustainable imports.

In practice, levers explored in the scenario framework include examples such as policies seeking to reduce food waste, those which shift diets away from high-impact commodities, those which improve material efficiency or support alternative products, and those that apply carbon-related or biodiversity-related import cost signals. Taken together, these measures support a more holistic approach to reducing the EU’s footprint, going beyond just de-risking supply.

The policy options explored in the analysis act as examples rather than a comprehensive suite of consumption-linked and circular-economy levers. However, they can still achieve substantial footprint reductions. The chart below shows how the modelled EU deforestation footprint changes across different policy combinations and ambition levels, including when EUDR-style de-risking is added to broader policy packages.

On their own, higher ambition combinations of these broader measures reduce the modelled deforestation footprint by 39.8%. When combined with EUDR-style scenarios, the reductions are larger still. Pairing high ambition non-EUDR measures with low ambition implementation of the EUDR reduces the modelled footprint by 60.0% relative to the baseline. Pairing high ambition non-EUDR measures with high ambition EUDR reduces it by 85.3%.

“The findings suggest that the EUDR will be a critical mechanism for reducing the EU’s footprint, and the difference between results of our lower ambition and higher ambition scenarios clearly illustrate the potential importance of strong implementation, despite all the delays the EUDR has faced,” says Chris West, Trase co-director and co-author of the report. “That said, the EUDR is only one measure and could be usefully and impactfully complemented by a wider set of measures linked to the EU’s circular economy transition.”

Croft, S., Vrijhoeven, R., Green, J., Simpson, J., Molotoks, A., Stokeld, E., Taherzadeh, O., & West, C. (2026). Expanding the toolkit: Exploring European policy pathways to reduce agricultural deforestation and biodiversity loss. Trase. https://doi.org/10.48650/4Y4G-R916