Undermining Forest Protection through Deregulation

While the European Commission has listened very well to the corporate calls to cut red tape in the EUDR and CSDDD, the call for smallholder support has been largely ignored. In the preamble to the EUDR, the EC recognizes the importance of responsible procurement to support smallholders: "When sourcing products, reasonable efforts should be undertaken to ensure that a fair price is paid to producers, in particular smallholders, so as to enable a living income and effectively address poverty as a root cause of deforestation".

However, in practice we see that the EUDR has strengthened the tendency of importers to impose top-down sustainability requirements on growers, both large and small. Smallholders are often ill-equipped to comply. As one anonymous palm oil processor stated in an interview for the Palm Oil Barometer: "Buyers constantly stress that materials must be delivered in accordance with NDPE-requirements, but smallholder inclusion and reward for sustainable performance are not deal-breakers for them".

To truly uphold the UN's guiding principle of "leaving no one behind" and to prevent further marginalization of smallholders from the EU, the Commission and Member States must ensure that implementation of the EUDR actively promotes smallholder inclusion. This requires targeted support, particularly in addressing traceability - an area where smallholders face structural barriers.