A HOLISTIC APPROACH TO FIGHT DEFORESTATION
Deforestation and forest degradation are important drivers of global warming and biodiversity loss — the two key environmental challenges of our time. The main cause of these problems is the expansion of agricultural land, which is linked to the production of commodities. The Food and Agriculture Organization of the United Nations (FAO) estimates that 420 million hectares of forest — an area larger than the European Union — were lost to deforestation between 1990 and 2020.
On November 2021, in the wake of the Glasgow Climate Change Conference (COP26), the European Commission launched a proposal for an EU Regulation [1, 2] to minimize the risk of deforestation and forest degradation associated with commodities and products placed on the EU market. The Proposed Regulation fits in the wider context of the European Green Deal (EGD), the Commission’s flagship initiative to transform the EU from a high- to a low-carbon economy. The EGD will not only influence nearly all decisions made by the EU Commission, Parliament, and Council in years to come, it will also impact all industries including the cosmetic and personal care industry.
The wider goal of the proposal is to reduce greenhouse gas emissions and global diversity loss, by minimizing the consumption of products from supply chains associated with deforestation or forest degradation. This regulation follows similar initiatives in other countries, such as the United States (FOREST Act 2021)  and United Kingdom (Environment Act 2021) . Being some of the largest consumers of agricultural commodities, the introduction of deforestation legislation in those important areas could be the start of a larger global effort to address one of the most environmentally harmful practices using trade measures.
The Proposed Regulation in Europe covers six commodities (cattle, cocoa, coffee, palm oil, soya, and wood) as well as products that contain, or have been fed or made with them. The list is likely to be extended over time. This law prohibits placing or making available on the EU market the listed commodities and products, unless they are deforestation-free, produced in accordance with the relevant legislation of the country of production and covered by a due diligence statement. A deforestation-free label will be awarded to commodities deemed not to have been produced on forest land converted to agricultural use after December 31, 2020.
The substantive legislation would be imposed at EU level and Member States would be tasked with the enforcement of the Proposed Regulation, in cooperation with the EU Member State customs authorities. The competent EU Member State authorities would have to carry out comprehensive checks to establish compliance by operators, pursuant to detailed criteria and risk analyses. EU Member States would have to ensure that these annual checks cover at least 5% of the relevant operators as well as 5% of the quantity of each of the relevant commodities placed or made available on or exported from their market. For countries categorized as high-risk, enhanced scrutiny would be required, whereby at least 15% of relevant operators and 15% of relevant commodities would have to be checked.
The Proposed Regulation has been also subject of debate and controversy in some aspects. For example, a key element is that it not only covers deforestation, but also forest degradation, which has been imprecisely defined. It is also notable for what it does not cover, for instance some commodities as rubber and rubber products are not listed. Similarly, it only covers forests and not other ecosystems such as land with high carbon stocks or land with high biodiversity value, such as grasslands, peatlands, or wetlands.
Which measures are already taken in this context to fight against deforestation? Certain strategies that are currently being used can help to reduce it. For example, the planting of trees to offset carbon emissions has become a popular way of helping corporations reach green targets. Emissions that can’t be avoided or reduced further during manufacture are climate-neutralized via carbon offsetting through afforestation projects by some companies.
Another approach is the No Deforestation, No Peat, and No Exploitation (NDPE) policies which is one of the most important commitments that has been made to date by the agricultural industry. Agriculture and forests must coexist in a sustainable way and the NDPE goals are all focused on protecting our planet’s resources and the people who grow them and live among them.
‘No deforestation’ is typically achieved through protecting High Conservation Value (HCV) and High Carbon Stock (HCS) areas, ‘No Peat’ through avoiding planting on peatland, and ‘No Exploitation’ through protecting human rights, workers’ rights and the rights of local communities and indigenous peoples.
The palm oil industry has pioneered the use of this type of sustainability commitment as part of its efforts to create transformational change in the supply chain, and today most the world’s largest palm oil producers and traders have comprehensive commitments to NDPE.
As a conclusion, deforestation is a hot topic that is being addressed both from the legislation point of view and from proposals for good practices from the industry. Only by using a holistic point of view can the worldwide fight against this environmental problem be carried out. For sure we will need to stay tuned on future updates, and the IFSCC 2023 Congress will be an excellent opportunity to debate and know more about this topic.