Mighty Earth & allies urge EC to ensure effective deforestation law

Read the letter here

Mighty Earth has today joined 40 organisations in sending a letter to the European Commission, warning against a potentially devastating self-inflicted blow to its efforts to halt global deforestation driven by EU consumption.

Having narrowly avoided a crisis of its own making by exposing the EU Deforestation Regulation (EUDR) to political attacks in October 2024, the European Commission is now at risk of committing another act of self-sabotage on the landmark law.

The Commission’s blunders in 2024 resulted in a one-year delay to EUDR implementation. And now, in a desperate bid to appease unhappy trade partners (including those with high rates of deforestation), officials from the Commission have suggested that only countries under some form of UN sanctions would be labelled as “high risk” origins for agricultural commodities covered under the law.

Just to be clear: what they would NOT be checking for are, for example, the extent to which humanrights violations or illegality are linked to agricultural commodity products flowing to the EU. Nor even rates of deforestation or forest degradation. 

This means countries would not be risk-assessed for issues such as the extent to which human rights violations or illegality are linked to the production of agricultural commodities, nor even the rates of deforestation or forest degradation linked to products coming from those places. This clearly makes no sense.

The so-called “risk benchmarking methodology” is a critical tool to enable those enforcing the law in EU member states to take action to stop ‘imported deforestation’ goods entering the Common Market. It is supposed to help law enforcers do their job more effectively, by empowering them to conduct frequent checks on companies bringing in products coming from high-risk areas, whilst taking a more relaxed approach to those originating from low-risk regions.

But for this system to work, the risk ratings must be gauged using sensible criteria; ones linked to the Regulation’s intended purpose.

In our letter, we call for the Commission to:

• Not use UN sanctions as the main or sole criteria to determine whether a country or parts thereof are high risk
• Instead, to consider human rights violations and risks of illegality from the outset for all countries, consistently with Article 29(4)(c) and (d), including for countries with low deforestation or forest degradation rates
• Also, to consider forest degradation alongside deforestation, which is consistent with the text of the regulation
• Examine production trends for all commodities covered by the EUDR, not just a select few
• Not unduly characterize trade agreements between the EU and other countries as ‘neutralising’ risks of deforestation, illegality, and rights violations.