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EU Forests Regulation Public Consultation – Indonesia Responds

Indonesian Palm Oil Association (GAPKI) has made its submission to the EU Forests Regulation public consultation on reducing deforestation and forest degradation.

As background, the European Commission is proposing a Due Diligence regulation to tackle deforestation / forest degradation with the aim to prevent European imports and consumption ‘causing’ deforestation, particularly from tropical forests.

To be clear: the Indonesian palm oil community broadly supports policies to prevent deforestation, and believes that this should take place with enforcement and compliance at the domestic level. An indirect measure that curbs trade and exports from developing countries to the European Union – such as a unilateral EU regulation – will not stop deforestation, and will instead undermine efforts to combat it.

It is also GAPKI’s view that introducing unilaterally developed sustainability criteria for a Due Diligence regulation will disrupt trade between the EU and Indonesia, undermine the recent signing of an EU-ASEAN Strategic Partnership and may consequently expose any European Union regulation to challenges under the WTO Agreements.

Moreover, GAPKI believes Indonesia’s legality and sustainability certification system for palm oil (ISPO) can and should serve as the basis for sustainability and legality assurance for any European Union due diligence requirements going forward.

Key points from GAPKI’s submission: 

  • Indonesia has reduced its deforestation rate thanks to legislative and private sector initiatives;
  • Palm oil is not a major contributor to Indonesian deforestation;
  • Palm oil plays a significant role in the Indonesian economy and is a key part of Indonesia’s trade relationship with the EU;
  • Indonesia and the EU have successfully cooperated on illegal logging, and a similar approach could be extended to palm oil;
  • The EU should recognise ISPO in any due diligence regulation it is proposing; and
  • GAPKI underlines that any regulatory measure should:
    • not discriminate against Indonesia;
    • not discriminate against palm oil;
    • provide a level playing field for certification;
    • preference legality rather than sustainability; and
    • uphold Indonesian sovereignty.

The European Union should work with Indonesia’s palm oil community using the tools that have been developed by Indonesians for local and national circumstances. This is the best approach for sustainable development and for aligning with international definitions of sustainability under the United Nations Sustainable Development Goals.

Why is GAPKI Not Endorsing TFA’s Position?

The EU consultation has sparked interest among many stakeholders in the palm oil world, including NGOs. Tropical Forest Alliance (TFA) is asking for public support for its position, including asking Indonesian bodies to support.

GAPKI reviewed their request, and has decided not to support their position.

First, GAPKI and the Indonesian palm oil community broadly support the TFA’s objectives regarding policies to prevent deforestation in countries such as Indonesia and Malaysia.

However, TFA’s position in response to the EU Public Consultation is erroneous with regard to both Due Diligence and certification.

Therefore, despite sharing similar concerns regarding policies to prevent deforestation, GAPKI’s position diverges from TFA’s and cannot be supported.

TFA acknowledges that the bilateral VPA (voluntary partnership agreement) approach provides a valuable approach for commodities. TFA is well aware that the VPA approach has legality – rather than sustainability – at its core.

Despite this, TFA recommends moving well beyond a legality framework and launching straight into a sustainability framework. At the same time, TFA dismisses both voluntary and mandated certification schemes – which are arguably the best and ‘market ready’ tools for both legality and sustainability – as inadequate.

Indonesia has repeatedly pointed to the international consensus reached on the UN Sustainable Development Goals as the starting point for sustainability, and ISPO as the starting point for sustainability for Indonesian palm oil.

It is therefore disappointing that neither the SDGs nor national standards are the primary focus of the TFA’s position paper, despite the latter being referenced numerous times during a July workshop.

You can find the response to the TFA position in full here.

You can find the response to the EU Public Consultation in full here.

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