ClientEarth position paper to the public consultation ‘Deforestation and forest degradation – reducing the impact of products placed on the EU market’

ClientEarth advocates for a mandatory due diligence framework for all companies placing forest-risk commodities on the EU market, arguing that such a measure would be more effective than voluntary schemes or certification. The organization emphasizes that due diligence must extend beyond mere compliance with producer-country laws to include the protection of indigenous peoples' land rights and other natural ecosystems. Additionally, ClientEarth calls for the inclusion of the financial sector in the legislation, the strengthening of forest partnerships with producer countries, and the reform of Free Trade Agreements to ensure binding environmental and social standards.

• ClientEarth supports the implementation of a mandatory due diligence framework for forest-risk commodities, noting that a European Parliament assessment found this option could "decrease deforestation and associated carbon emissions by 62% compared to the baseline".
• The organization argues that due diligence criteria must go beyond compliance with the laws of producer countries because national legal frameworks are often "incomplete or contradictory" and "sporadically or selectively implemented", which can lead to accelerated deforestation.
• ClientEarth asserts that legislation must explicitly protect the land tenure rights and resources of Local Communities and Indigenous Peoples (LCIPs), as laws in producer countries are frequently "non-existent, weak, or very poorly applied".
• The proposed regulatory framework should apply to "companies of all sizes" to prevent loopholes that occur when minimum thresholds are set too high, allowing smaller companies with riskier supply chains to avoid requirements.
• ClientEarth recommends that the European Commission include the finance sector in its legislative proposal, citing that forest-risk commodity companies in Southeast Asia, Brazil, and Central and West Africa received over "USD 153.9 billion in credit" between 2016 and 2020.
• The organization maintains that certification and industry-led schemes are "no substitute for rigorous due diligence" and should not be used as sole evidence of compliance, mirroring the approach of the EU Timber Regulation.
• ClientEarth suggests that Free Trade Agreements (FTAs) require fundamental reform to include mechanisms for effective monitoring of impacts and the "Proper enforcement of meaningful commitments to key international environmental and social standards".

APA

ClientEarth (n.d.). ClientEarth position paper to the public consultation ‘Deforestation and forest degradation – reducing the impact of products placed on the EU market’. https://www.clientearth.org/media/w1qdlnmk/clientearth-position-paper-to-the-ec-deforestation-public-consultation.pdf

Chicago

ClientEarth. ClientEarth position paper to the public consultation ‘Deforestation and forest degradation – reducing the impact of products placed on the EU market’. n.d. https://www.clientearth.org/media/w1qdlnmk/clientearth-position-paper-to-the-ec-deforestation-public-consultation.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth position paper to the public consultation ‘Deforestation and forest degradation – reducing the impact of products placed on the EU market’ |url=https://www.clientearth.org/media/w1qdlnmk/clientearth-position-paper-to-the-ec-deforestation-public-consultation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearthndclientearth, author = {{ClientEarth}}, title = {{ClientEarth position paper to the public consultation ‘Deforestation and forest degradation – reducing the impact of products placed on the EU market’}}, publisher = {ClientEarth}, url = {https://www.clientearth.org/media/w1qdlnmk/clientearth-position-paper-to-the-ec-deforestation-public-consultation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }