The European Parliament and member state ministers have formally approved the one-year extension of the European Deforestation Regulation (EUDR). Importantly, they did this without making any changes aimed at diluting its impact. It is hoped that this will bring an end to a period of uncertainty and difficult debate.
But even though that is accomplished and the holiday season is about to begin, there is no time to really relax. The real challenge for the EUDR is about to begin. How do we deliver on the EUDR’s commitments, and how do we actively implement it for the communities at the heart of its implementation: small-scale producers around the world?
This is no small matter, and currently stakeholders lack the tools necessary to ensure that smallholder farmers are part of the EUDR solution and do not fall victim to its chaotic delivery. EUDR needs meat on its bones too. We need to assess the impact and work to develop the guidelines and framework needed to make the EUDR successful. And we need partnerships and funding to power the EUDR. I don’t really have time to relax.
The impact of the EUDR on producing countries needs to be mapped and monitored
In recent months, the core aspects of EUDR implementation and all the work that goes with it have taken a backseat in the political arena of EUDR delays. This delay was specifically proposed to address a lack of implementation details, but there was a deafening silence on the topic. Stakeholders supporting the EUDR fear that the EUDR will be used as a whip against the EUDR by stakeholders on the other side of the debate who seek to exaggerate any potential negative consequences of the EUDR. Elements were also afraid to criticize. EUDR. Much of this criticism focused on the negative impact on smallholder farmers, but it was never easy to separate genuine concerns from corporate opportunism.
It is important to better understand which concerns are truly legitimate and which are not. Now that the political issues are out of the way, it’s time to get back to reality and act on what’s actually happening, or what’s likely to happen, on the ground. Solidaridad and other NGOs are committed to carrying out a sound impact assessment to understand how the EUDR is likely to impact the most vulnerable smallholders in different sectors and regions. I’ve been advocating this for quite some time.
Without this public and private stakeholder commitment to implementation, the EUDR will be implementing in the dark. And they will be operating in the dark for some time to come. The EU refuses to endorse an impact assessment until 2029. All the while, without an evidence-based approach, the chances of stakeholders stumbling on something in the dark are nearly 100. %
Several producing countries are studying the potential impact of the EUDR at the request of NGOs, companies, the World Bank, and even the European Union. However, this is a very decentralized approach and some research is not publicly available. Currently, there is too little time to conduct a centrally organized pre-assessment. In return, the EU should support the establishment of a monitoring body to study and monitor the expected and actual impacts of the EUDR in affected regions. This at least allows stakeholders to adapt their approaches and techniques as more data becomes available.
Processes need to be clear and streamlined
Perhaps unsurprisingly, scattered impact studies have been complemented by a very sloppy approach to implementation support.
For example, after so many delays that the EUDR had to wait another year, the European Commission finally published FAQs and guidelines for EUDR stakeholders. Unfortunately, these guidelines leave many questions unanswered. Consider, for example, a sentence that refers to legal compliance with human rights. The guidelines here are so vague that I have yet to meet anyone who can explain what this would actually look like. What’s worse, in many issues it’s completely unclear where the metaphorical burden stops. For much of the EUDR practice, the European Commission directs interested parties to the relevant “competent authorities” or Member States, who in turn point directly to the European Commission.
To deal with this unclear advice and the confusion of unclear roles and responsibilities, Member States, the European Commission and competent authorities have established the EUDR Standing Committee, which works in close cooperation with companies, NGOs and producer countries. should be established. This allows us to work together to find practical ways forward and bring clarity to everyone affected.
EUDR requires dialogue, partnerships and funding
Perhaps most importantly, little attention has been paid to the dialogue and partnerships with producing countries that are essential to the success of the EUDR. This is despite Article 30 of the EUDR requiring stakeholders to address the root causes of deforestation, such as compliance and smallholder poverty.
After 15 months, the European Commission has now presented an inadequate and widely disappointing strategic framework for engagement in international cooperation. A framework is primarily an overview of existing programs. The Team Europe Initiative funding to support implementation is €80 million from just two member states. This is a small step in the right direction when you need to take strides.
Ambitious partnerships with producing countries are essential to make the EUDR work for both nature and people at the start of global supply chains. These need to be tailored to the scale of the challenge, focus on addressing the root causes of deforestation, and include support for the millions of affected smallholders.
