On 18 December 2018 the European Commission released a ‘Roadmap’ that outlines the initiatives it proposes for “stepping-up EU Action against Deforestation and Forest Degradation”.  The Roadmap responds to a long process of investigation, study, and policy deliberation set in train in 2008 by the Commission Communication on deforestation and forest degradation.  In the decade since, the necessity for decisive action to address the growing trend of EU consumption of forest-risk commodities and increasing contribution to global deforestation has been expressed in various EU strategies (eg. the EU Forest Strategy), programmes (eg. the EU Environment Action Programme to 2020), reviews of existing forest governance and timber industry initiatives (eg, the Forest Law Enforcement, Governance and Trade Action Plan), and policy commitments (eg. the 2017 European Consensus on Development).

EU's contribution to deforestation is rising every year

 Despite the abundance of existing policies and non-binding measures, as well as numerous private sector commitments and voluntary certification schemes, the consumption of forest-risk commodities in the EU, and the EU’s contribution to global deforestation, has risen steadily year on year.  In response to the apparent ineffectiveness of existing measures, the European Parliament has repeatedly called on the Commission to develop concrete and coherent regulatory measures to address EU trade and investment in forest-risk sectors (eg on 4 April 2017, on 4 July 2018, and 11 September 2018) and a number of EU member-states have called for “an ambitious EU Action Plan on deforestation and forest degradation“ (eg. the call from Italy, France, Germany, the Netherlands, Denmark, Norway and the United Kingdom on 1 November 2018).  The Commission’s own Feasibility study on options to step up EU action against deforestation, published on 19 March 2018, concluded that new legislative measures combined with coherent policy initiatives would have the greatest impact and deliver the most effectiveness, though also requiring the largest effort on the part of the EU.

Deforestation and  human rights violations highly linked to EU

Both ENDS and the Forest Peoples Programme, together with partners from Europe and tropical forest countries, have made repeated visits to Brussels to speak with Commission representatives and emphasise the systemic patterns of human rights violations, environmental damage, displacement, physical and sexual violence, corruption, intimidation and murder of local communities, their leaders and human rights defenders linked to the expansion of forest-risk sectors in producing countries.  It appears the testimonies of human rights defenders and community leaders describing the first-hand impacts of deforestation linked to European supply chains have fallen on deaf ears.

Decisive and binding action to reduce EU demand for forest-risk commodities and investment in forest-risk sectors could both prevent violence in producing countries and support efforts to protect the livelihoods, land rights and food and water security of local communities, while also supporting the EU’s efforts to implement the Sustainable Development Goals and reducing the EU’s contribution to global climate change.  The challenge of tackling the negative impacts of the global agricultural system is immense, but it is absolutely essential to efforts to halt global deforestation and prevent dangerous climate change – goals to which the EU has unequivocally committed.

New EU roadmap with measures to counter deforestation is very weak and dissappointing

Despite the importance of these objectives, the mounting evidence of the EU’s contribution to the problem, and the policy-making mandate for regulatory measures conferred by the European Parliament, the ‘roadmap’ of measures proposed by the Commission sets the woefully inadequate and sadly unambitious aim of “a more coherent policy framework for existing policies and tools”.  In doing so, the Commission has unreasonably limited the scope of potential measures and ignored the recommendations of its own Feasibility Study for “a more coherent and comprehensive EU approach” acting on multiple levels, of which legislative measures offer the greatest chance of impact.  Instead, the Commission has opted for the relatively easier, yet most-likely ineffective option of tinkering with existing initiatives and policies – an approach described in the Feasibility Study as being least effective and having the lowest likely contribution to the objective. 

The Roadmap is equally silent on the human rights dimension of deforestation, how the proposed measures will support the EU’s existing human rights obligations and sustainable land governance commitments (for example, the UN Declaration on the Rights of Indigenous Peoples and the FAO Voluntary Guidelines on the Responsible Governance of Tenure), or support secure tenure rights of forest communities and indigenous peoples in producing countries – proven to reduce deforestation effectively and efficiently.

Inputs into EU Commission’s proposals 

The Roadmap was open for feedback until 15 January 2019.  In the hope of alerting the Commission to the importance of its task and the evidence supporting an escalation in effort, Both ENDS and the Forest Peoples Program together with six partners from tropical forest countries made a written submission emphasising our concerns and recommendations.  We hope our input will prompt the Commission to reconsider the scope of appropriate and justified measures required to address the EU’s contribution to global deforestation.

An online questionnaire about the Commission’s proposed approach was open for input until 25 February 2019. Both ENDS and partners also submitted a position paper during this second round of consultation.