JOINT POSITION: European Forest Owners and Managers’ considerations on the EC Proposal for a Deforestation and Forest Degradation Regulation

The proposal for a Deforestation and Forest Degradation Regulation, published by the European Commission on 17 November 2021, risks missing its aim due to inadequate definitions and unfeasible provisions for monitoring and implementation.

While forest managers and owners support the general objective of the EU initiative to curb global deforestation caused by EU consumption of certain products and commodities, we remain convinced that this should be achieved by strengthening existing governance frameworks for active and sustainable forest management. In the context of EU forests, this requires a coherent political framework with proportionate provisions regarding environmental objectives and climate change, but also economic aspects, trade, the bioeconomy, and the viability of rural areas. Extensive experience in setting provisions regarding sustainable and multifunctional forestry lies with EU Member States and is in effect implemented by forest owners and managers. Unfortunately, the approach proposed by the Commission essentially overlooks this experience and thereby hinders finding an appropriate way forward. Therefore, as forest owners and managers, we would like to bring the following considerations to the attention of EU co-legislators with the hope of developing a legislative framework that will bring added value.

Key take-aways: 1. Definitions should be workable and consistent with international forest reporting, thus adapted to the diversity of forests throughout the world 2. Monitoring of forest degradation needs to build on reliable methods 3. Country benchmarking should follow a transparent and comparable process 4. Obligations related to country risk categories should be differentiable and adjusted to the actual risk of deforestation 5. Requirements for operators need to be proportionate and implementable 6. Access to justice and entitlement to submit substantiated concerns need to be better balanced