The European Commission’s (EC) push for deforestation-free products in the agricultural supply chain has raised concerns from European Union (EU) trade associations representing the grain, oilseeds, crushing and animal feed sectors following the EC’s adoption on 28 June of the General Approach of the Environmental Council on the proposal.
In a joint statement, the three trade associations – EU vegetable oil and protein meal industry association (FEDIOL), EU trade association for cereals, rice, feedstuffs, oilseeds, olive oil, oils and fats (COCERAL) and EU feed manufacturers’ federation (FEFAC) – welcomed some elements of the proposals such as the council’s move to avoid duplication of due diligence.
However, they expressed concern that no significant changes were put forward on traceability, cooperation with third countries, and chain of custody.
“Even if some farmers are able to comply with this [traceability to plot] requirement, collecting geo-location data of smallholders and cooperatives faces important technical, logistical, legal and governance challenges which cannot be addressed by companies alone,” the associations said in their 29 June statement.
“If such challenges are not solved under a multi-stakeholder approach involving local governments, local industry actors, EU operators, the European Commission and NGOs, companies will not be able to collect reliable geo-location to plot information for the majority of smallholders currently part of their supply chains.”
The associations urged the EC to tackle the challenges through forest partnerships, development assistance and any other available means before implementing and enforcing the regulation’s geo-location to plot requirement.
While the EC’s proposal did not explicitly refer to the required chain of custody for delivering deforestation-free products, its inclusion of “risk of mixing with products of unknown origin or produced in areas where deforestation or forest degradation has occurred or is occurring” as part of an operator’s risk assessment pre-supposed that deforestation-free products could not be physically mixed with products which had not been verified as “deforestation-free”, the organisations said.
“If this type of mixing is not allowed…, it will have a disruptive, trade distorting effect on global soyabean supply chains to the EU while undermining deforestation-free commitments and efforts already undertaken in high-risk areas,” the statement said.
“It would require building new infrastructure (country elevators, silos, crushing lines or plants, port loading) at such prohibitive costs that operators in most large ports are likely to abstain from the investment,” the associations added. “As a result, supply flows into the EU are expected to be considerably reduced and to switch from high-risk to low-risk areas, abandoning all positive engagement and incentives to farmers to halt deforestation.”
The associations said the industry was ready to work with the EC and other stakeholders to address the challenges.