The International Tropical Timber Organization (ITTO) and Indonesian stakeholders have raised concerns indicating that concerns about the European Union Deforestation Regulation (EUDR) extend beyond palm oil, encompassing the agriculture and forestry sectors. This issue was a focal point of discussion during the Trade and Markets Day at the 59th session of the International Tropical Timber Council in Pattaya, Thailand.

The Council’s session provided a platform for varied presentations by global experts, culminating in the Annual Market Discussion organized by the ITTO Trade Advisory Group (TAG). A key segment of the Day, hosted by the Civil Society Advisory Group (CSAG), delved into the implications of the EUDR for smallholders and community forestry.

Chandra Silori, Deputy Executive Director of RECOFTC, the world’s leading organisation for agroforestry smallholders, highlighted the regulation’s challenges for smallholders, who will likely face increased demands for information, such as land geolocation, and greater scrutiny of compliance with national laws.

Silori pointed out clear challenges for smallholders in Indonesia and Thailand:

  • High operational cost affects the ability of smallholders to meet requirements of EU buyers and traceability
  • Poor mapping of plots, and lack of legal tenure risks exclusion from EU supply chain
  • Aligning EUDR’s deforestation definition with national legal definitions
  • Value chain governance – trust, transparency, and inclusion of smallholders.

Stephen Midgley, speaking during the Annual Market Discussion, echoed these concerns, noting that the EUDR and similar trade-related regulations increase costs for small growers without compensation.

Concerns were also raised by Franz-Xaver Kraft of GD Holz Service GmbH and Nils Olaf Petersen of GD Holz and the European Timber Trade Federation. They pointed out the potential for “substantiated concerns” submissions to lead to investigations by authorities, which could disrupt legitimate trade and pose major compliance challenges, especially for smallholders.

ITTO members, including Brazil, New Zealand, Peru, the United States, and Viet Nam, intervened on the EUDR-related discussions. Issues raised included the regulation’s potential impacts on smallholders, complexities in timber product supply chains, and concerns over whether activities like replanting after wildfires would count as deforestation under the EUDR.

The TAG’s statement acknowledged the principle behind the EUDR but expressed deep concern about aspects that could create barriers to sustainable tropical forest resource development and trade. They urged the EU to consider these concerns and the positive contribution of legal tropical forest product trade in mitigating deforestation risks.