Comments on the "Guidance Document" for the EU Deforestation Regulation
Year: 2024
Type: article
Abstract: Supplementary material to the paper "Definitional confusion and collateral damage due to new deforestation-free trade policies" which is currently under peer review. Available on EarthArXiv In response to various questions and comments the European Commission prepared a guidance document that was circulated in confidential circles in April 2024 and finally, with minor modifications, released on 2.10.24. The document has a low legal status, as clarified in a footnote : “Nothing in this guidance document either replaces or substitutes direct reference to the instruments described and the Commission does not accept any liability for any loss or damage caused by errors or statements made in it. Only the European Court of Justice can make final judgments on the Regulation’s interpretation.” Seven pages of the text aim to clarify key concepts of "deforestation’ as the start of agricultural use" The text was clearly written from a European perspective and frame of reference, where ... A conceptual segregation of agriculture and forest as separate sectors and actors is taken as a given. Agroforestry is an afterthought, rather than part of the initial problem analysis and framing, despite its role in the production of the targeted commodities outside of Europe. Swidden/fallow cycles are no longer part of the collective memory. Privatization of formerly communal land is assumed and no institutions between individuals and state are acknowledged A ‘single actor, single purpose’ view on land use prevails with little understanding of multifunctional, multi-stakeholder landscapes. A belief that strongly disaggregated spatial data can be correctly interpreted in a black-white forest-agriculture language by external EUDR agents without knowledge of local context. The text falls short of appreciating the reality of the landscapes in which large parts of the seven ‘deforestation-risk’ commodities are produced – and the differences between soybean, cattle, palm oil, cocoa, coffee and rubber production in this respect. Wood products are considered to be deforestation-free by definition and subject to forest degradation rules yet to be clarified. There is no reference to the definitional confusion that arises where ‘EUDR forest’ concepts differ from the ‘UNFCCC forest’ used for by all countries for annual or bianniual reporting of climate emissions and land use change. Greater subsidiarity and adjustment to national circumstances would have been preferred. Yet, in a few places an underlying interest in protecting a ‘core forest’ concept as ultimate rational of the policy shines through – which could be a good direction to explore further.
Language: English
Subfield: Global and Planetary Change
Field: Environmental Science
Domain: Physical Sciences
SDG: Life on land
Open Access status: green
OpenAlex ID: W6893230799
FWCI:
Cites:
Cited by:
Related to: