Sustainability is shaped not only by regulation, but by the realities of people, landscapes and supply chains on the ground. Drawing on recent EUDR training programs, our Sustainability Specialist, Paul, reflects on the gaps he witnessed between policy and practice and what it takes to turn sustainability commitments into meaningful action.
Q: When you look at EUDR from a bird’s-eye view, what do you believe is the underlying vision?
Paul: EUDR is aligned with the international climate goals of the Paris Agreement, as well as with the Kunming–Montreal Global Biodiversity Framework. The aim is to reduce global carbon emissions and to protect biodiversity.
Both are closely connected to deforestation. Deforestation and land-use change for agriculture are major contributors to global carbon emissions. Deforestation is also one of the primary drivers of biodiversity loss because natural habitats are being destroyed. So, the basic idea is that the European Union wants to reduce the footprint of European consumption on the global environment. It is trying to do this from the market side: reducing European demand for commodities linked to deforestation and placing the responsibility for that on European operators. By requiring European companies to scrutinize their supply chains, this pressure travels through the supply chain and eventually influences production practices in origin countries.
In principle, I think that makes sense. But in practice, supply chains are vastly different and operate within very different economic, institutional and cultural realities. That is where the relatively clear vision of the regulation starts to become much more complicated.
Q: What has struck you most about the difference between how compliance looks on paper and how it unfolds across the supply chain?
Paul: What has struck me most, after working on this regulation for around two and a half years, is that it often feels as though it was shaped by European bureaucrats who are not necessarily very familiar with the supply chains they are trying to regulate. There seems to have been a somewhat simplified and Eurocentric view of how these supply chains work.
The idea that European operators should gather a high level of detailed documentation for every supply chain is extremely challenging in practice. Depending on the origin, the documentation that the European Union expects companies to have may simply not exist. Different supply chains operate in completely different local and cultural contexts.
On the one hand, this creates a huge hurdle for smaller producers. European buyers, of course, do not really have an option other than to comply with the regulation. They therefore need to make a decision: either impose these requirements on their smallholder suppliers or accept a significant risk of non-compliance and the potential financial consequences themselves. On the other hand, the core idea of deforestation is itself defined very much from a European perspective. That creates a moral conflict. The European Union essentially accepts deforestation that happened many years ago, including within Europe itself. There is very little primary forest left in much of Europe, so the present-day risk of deforestation is relatively low.
So, the regulation penalizes countries that still have significant primary forests. Of course, the ambition is to protect those forests, which makes a lot of sense. But it also limits the autonomy of producers, communities and producing countries to decide what to do with their own resources.
"In practice, supply chains are vastly different and operate within very different economic, institutional and cultural realities. That is where the relatively clear vision of the regulation starts to become much more complicated."
I saw this very clearly during a recent field trip to Peru. The local communities have a very intimate relationship with their surrounding ecosystem. They distinguish between primary forest, regenerating forest and fellow land that was productive a few years ago, is now regenerating and may become productive again in the future. The latter was referred to locally as 'purma'.
The conversion of purma was not considered deforestation by the local communities, but these local landscapes do not necessarily fit neatly into the categories defined by the regulation. That really showed the conflict between how the regulation was thought through on paper and how it may create unintended or adverse impacts for communities in sourcing areas.
