Unsustainable deforestation and commodity imports. Public consultation on EU strategy


The European Parliament, in a resolution 22.10.20, called on the Commission to take strict measures on theimport of commodities linked to deforestation. The EU must take responsibility for its own responsibility in environmental degradation caused by its own trading partners in third countries and assert an effective strategy to protect forests and biodiversity. A public consultation on the subject is now underway.

One Disease

International demand for unsustainable agricultural commodities has a direct impact on environmental, animal and plant health. One Disease, as opposed to the One Health paradigm promoted by theWorld Health Organization (WHO). Forests and forests still cover 30 percent of the earth’s surface but have more than halved in the past 60 years, mainly due to fires and deforestation (1).

Deforestation is also the main cause of animal extinction. In just the past 50 years as many as 58 percent of vertebrate species have disappeared due to these causes. (2). With serious damage also to indigenous peoples, that is, 25 percent of the global population, who still derive their livelihood from interaction with nature. (3)

Less forest, more desert

Forest protection is crucial to prevent desertification and to preserve waterways even thousands of miles away. The Ethiopian highlands at the source of the Nile, for example, owe their rainfall to the moisture caused by the Congo forests. Nor is reforestation enough to compensate for the devastation of primary forests, for several reasons.

Deforestation of areas that constitute large carbonstocks (High Carbon Stock) causes greenhouse gas emissions that are expected to continue for 7-8 decades. And the environmental impact of land conversion-for agricultural use, in 80 percent of the affected areas-is as irreparable as the loss of habitat and biodiversity. (4) The European Parliament intends to propose primary forests as UNESCO heritage to ensure their effective and global protection. (5)

EU-tagged deforestation

The European Union is the leading global importer of raw materials related to deforestation and environmental degradation. Palm oil, soybeans, rubber, beef and leather from South America, corn, cocoa and coffee, as well as timber, eucalyptus, cotton, sugarcane, canola and mangrove-fed shrimp. Between 1990 and 2008, the EU is estimated to have contributed 10 percent of global crop consumption associated with deforestation in countries of origin, ‘consuming’ an area of forest equal to that of Portugal. (6)

The European territory in turn is home to 5 percent of the planet’s forests, and only here has there actually been a tentative recovery in the last 30 years. (7) Already outside EU borders, even worse in tropical areas, deforestation conversely is advancing rapidly, at a rate that has almost doubled in Brazil under Jair Bolsonaro. (8)

European Commission, the good intentions

The European Commission’s 23.7.19 communication had assumed five vague ‘priorities’, to ‘safeguard the forests’ of the planet:

– Encourage consumption in the EU of products with ‘deforestation-free’ supply chains. However, without considering the risks of greenwashing and omertà, already amply demonstrated in the RSPO self-certified palm oil supply chain,

– Cooperate with producing countries. Neglecting diplomatic attacks and claims by Indonesia and Malaysia to hide data on their palm oil production, which accounts for about 80 percent of global production,

– Promote international cooperation, to halt deforestation and encourage restoration of natural habitats,

– Fund ‘sustainable’ land use in third countries,

– Support information on forests and supply chains, support research and innovation. (9)

However, the European Union’s strategy, according to the Parliament, must be supplemented with measures that are binding on the sector’s operators, in awareness of Europe’s role-still the leading agricultural commodities trading area on the planet-and the global impact of its decisions in this regard.

European Parliament, binding measures

Resolution 20.10.20 of the European Parliament expresses a new determination, which undoubtedly responds to the environmental sensitivity of citizens as well as the interests of virtuous agribusiness supply chains. Words and self-certifications of convenience are not enough, we need to hold traders and users of imported agricultural commodities from outside the EU accountable, and introduce impassable limits on unsustainable imports of commodities.

Sustainable Development Goals(SDGs) in UN Agenda 2030, the Paris Agreement on Climate Change (2015) and the
European Green Deal
(2019) can never be achieved without taking measures that are fit for purpose and binding on stakeholders. (10) Pending, we add, a Constitution for the Earth.

GMO Soybeans

The Strasbourg assembly addressed the many objections of MEPs and civil society to the import of GMO food and feed, GMO soybeans in particular. By finally highlighting – as already demonstrated in our ebookGMOs, the Big Scam‘ – as almost all of the crops in question, including NBTs (New Breeding Technicques) – have been genetically modified For the specific purpose of resisting broad-spectrum herbicides (e.g., glyphosate, glufosinate, dicamba). With the consequence of encouraging the abuse of agrotoxics, which has already been recorded in various scientific studies.

GMO soybeans account for nearly half of EU imports of deforestation-related commodities and dramatically affect the Old Continent’s carbon footprint, thus surpassing China’s carbon footprint by +13.8 percent. Although the People’s Republic of China is the most populous country as well as the world’s leading importer of soybeans. Europe’s negative leadership in this respect is due to its Brazilian and Argentine suppliers of GMO soybeans. (11)

Sustainability in agriculture

The production and consumption of plant-based protein should be boosted through promotion of nitrogen-fixing crops such as legumes under the 2021-2027 CAP strategic plans. Crop rotations, cross-compliance, ecological schemes and agri-environmental measures, profitability. (12)

In turn, animal husbandry must improve in terms of sustainability, including by reducing dependence on feed materials (GMO soybeans first and foremost). And to this end, we add, it is imperative to pursue research in Europe on new eco-logical protein sources. ( 13)

Unsuitable certifications

The certifications adopted by corporations to self-accredit some of their supply chains–e.g., RSPO, Roundtable for (un)Sustainable Palm Oil–are clearly unsuitable to halt the ecocides still taking place. In addition to being unreliable, as shown in several scientific studies including those of the Zoological Society of London (2017, see https://www.greatitalianfoodtrade.it/idee/olio-di-palma-rapina-delle-terre-e-deforestazioni-un-milione-di-ettari-sfugge-ai-registri-di-rspo-denuncia-la-zoological-society-of-london) and Tomsk State University (Cazzola Gatti et al., 2018, 2020. SEE https://www.greatitalianfoodtrade .it/consum-attori/olio-di-palma-insostenibile-la-scienza-conferma).

We therefore need to introduce binding measures and affirm the responsibility of downstream operators-importers in the EU and their customers, in the processing industry as well as in wholesale and retail distribution-for the social and environmental sustainability of the commodities they process. In turn, the European consumer must be informed on the basis of objective criteria and independent third-party certifications, according to the criteria adopted by ISO (e.g., the ISO 14000, ISO 20400:2017).

Eco-traceability, bans and penalties

The sustainability of products could be ensured through the traceability of products from an ecological perspective, perhaps even with the support of public blockchain systems. This would encourage sustainable and equitable supply chains, also taking into account the interests of small and medium-sized ethical enterprises in Low and Middle Income Countries (LMICs) to export their commodities to the EU. (14)

A radical and ambitious breakthrough is therefore demanded by the European Parliament from the Commission. It is necessary to develop a proposal for a regulation to prohibit and sanction the introduction of products and/or raw materials into the domestic market that pose risks to forests and ecosystems. Also enforcing sanctions against banks and other entities operating in the EU that finance activities involved in unsustainable supply chains.

Environmental statements and due diligence

The certification schemes now in use, as noted above, are extremely varied. In most cases these are not international standards but purpose-built private schemes that turn out to be mere greenwashing operations. Or even worse, meaningless self-certifications such as the Codes of Conduct that the European Commission itself is now proposing to supply chain representations, ahead of the UN Food Systems Summit 2021.

The Timber Regulation (EU Reg. 2017/821), in the part dealing with due diligence requirements, is a good model for a uniform framework for environmental declarations. Which must be mandatory and consider the supply-chain in its entirety, rather than being limited to individual steps or processes. Such information will also have to come under the discipline of unfair commercial practices (Directive 29/2005/EC, implemented in Italy by the d.lgs. 206/05 as amended, c.d. Consumer Code). (15)

Mercosur and other treaties

The Mercosur agreement was(falsely) presented as an ambitious and balanced agreement capable of creating significant sustainable growth opportunities for both sides. Such agreements, however, should include binding standards for sustainable development, rather than merely declarations of intent. It is therefore no surprise that, in the absence of guarantees on compliance with environmental and health standards, France withdrew its accession to the agreement with the Mercosur countries in February 2021. (16)

Civil society for that matter, even on the other side of the ocean, continues to denounce how this agreement has in fact incentivized deforestation and investment by landowners on huge tracts of land violently taken from indigenous communities and local farmers, to increase exports of commodities unsustainable agriculture in the Old Continent. (17)

Fair trade

Peasant communities – for the sake of the
United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas
, adopted ON 19.11.18 – continue to be harassed by land robbery(land grabbing) and exploitation. With serious detriment to food sustainability, right to food and a dignified existence, possibility of safeguarding ecosystems. () Therefore, it is necessary to define a legislative framework consistent with the needs for their protection, which is legally binding. (18)

The fair trade model must therefore be encouraged as a paradigm for sustainable development that cannot neglect the basic human rights of populations, women and children first and foremost.

Land grabbing

The right to a healthy and healthy environment is a universal human right, reaffirmed in Sustainable Development Goals (SDGs) 13(climate action), 14(life below water), 15(life on land), among others. The European Parliament therefore calls on member states to support the recognition of this right at the next UN General Assembly. Defenders of the environment and the rights of local communities should find in the European Union an advocate capable of intervening and activating effectively.

Deforestation-mostly due to inadequate environmental policies, lack of governance and corruption-is associated with land robbery and conflict(land grabbing). Therefore, the European Union must include the protection of basic human rights (property and land and labor rights, first and foremost) within the new regulation. (19)

Permanent observatory

The current definition of forest does not allow an adequate distinction between natural (primary) forests and forest plantations where the economic function of the forest dominates over its other functions. This confusion can distort the collection and analysis of data on the state of the world’s forests.

The Strasbourg assembly therefore calls for the use of specific notions for the express purpose of distinguishing different ecosystems. And it welcomes the creation of a forest observatory that can collect data and information at both European and global levels. (20)

Public consultation

The EU Forestry Strategy can be declined in different ways, based on alternative policy choices that the Commission has subjected to a public consultation extended to member states and other stakeholders.

The public consultation-available online, at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12674-EU-Forest-Strategy-is also aimed at citizens, who will be able to express their opinions and petitions by 4/19/21.

‘One of the first conditions of happiness is that the link between man and nature shall not be broken’ (Leo Tolstoy)

Dario Dongo and Susanna Cavallina


(1) https://ec.europa.eu/environment/forests/deforestation.htm 2019 EU communication on deforestation and forest degradation.

(2) https://www.wwf.ch/it/media/la-popolazione-di-vertebrati-si-e-ridotta-del-60-a-causa-delluomo

(3) https://ec.europa.eu/commission/presscorner/detail/en/IP_19_4470 European Commission press release dated 23-7-2019

(4) TA (europa.eu) Europarliament Resolution 22-10-20, General Remarks par.7-8

(5) TA (europa.eu) Europarliament resolution 22-10-20, Communication and awareness raising par.81

(6) Study on the feasibility – Forests – Environment – European Commission (europa.eu)

(7) https://www.europarl.europa.eu/factsheets/it/sheet/105/l-unione-europea-e-le-foreste

(8) TA (europa.eu) Europarliament resolution 22-10-20, General Remarks par.3

(9) Deforestation – Forests – Environment – European Commission (europa.eu) 2019 EU communication on deforestation and forest degradation.

(10) TA (europa.eu) Europarliament Resolution 22-10-20, General Remarks par.11

(11) TA (europa.eu) Resolution of the Europarliament 22-10-20, EU measures and policy coherence, para. 73.

(12) TA (europa.eu) Europarliament resolution 22-10-20, General Remarks par.12

(13) TA (europa.eu) Europarliament resolution 22-10-20, Mandatory rules based on due diligence par.22

(14) TA (europa.eu) Europarliament resolution 22-10-20, Voluntary third-party certification and labels, Voluntary third-party certifications, para. 18

(15) https://www.risoitaliano.eu/mercosur-parigi-dice-no/

Alberto Galvi. France. No signature to trade agreements between the European Union and Mercosur. Geopolitical News

(16) Les accords Mercosur vus d’Amérique latine : 3 témoignages du Paraguay, de (…) – CCFD-Terre Solidaire (ccfd-terresolidaire.org)

(17) O povo brasileiro passa fome: Bolsonaro nega auxílio ao campesinato para produzir alimentos – MST

(18) TA (europa.eu) Europarliament resolution 22-10-20, Forest management, research and innovation par.104

(19) TA (europa.eu) Europarliament resolution 22-10-20, Deforestation and human rights, para. 63.

(20) TA (europa.eu) Europarliament resolution 22-10-20, Definitions, Forest Data and monitoring para. 82.