Getting to “deforestation-free”

The document addresses industry resistance to the proposed EU deforestation regulation, specifically the 'Geolocation Requirement' which mandates that operators collect latitude and longitude coordinates for all plots of land where covered products (cattle, cocoa, coffee, oil palm, soy, and wood) were produced. ClientEarth argues that traceability is indispensable for ensuring products are 'deforestation-free' and produced legally. It refutes claims that the regulation mandates specific supply chain models like 'identity preserved' or 'segregated' chains, clarifying that mixed-origin supply chains remain permissible as long as they are traceable. The briefing also contends that geolocation requirements will not necessarily exclude smallholders, noting that many in the cocoa and palm oil sectors already support transparency to improve their market position. Furthermore, it argues that compliance costs are likely to be negligible when implemented at scale and that voluntary certification schemes, while useful tools, cannot serve as automatic evidence of compliance due to documented shortcomings in governance and reliability.

• The proposed EU regulation requires operators to collect 'geo-localisation coordinates, latitude and longitude of all plots of land where the relevant [Covered Products] were produced' as part of their due diligence.
• The regulation does not mandate specific supply chain structures; operators are not required to use 'identity preserved' or 'segregated' models, and supply chains with products of mixed origin are permissible provided they are traceable.
• The Geolocation Requirement does not require operators to link every individual unit of a commodity (e.g., a single soybean or drop of palm oil) to a specific plot of land, but rather to identify all plots of land associated with the quantity of products supplied by a particular supplier.
• Traceability to the farm level is presented as feasible for smallholders, with evidence that 22.8% of global cocoa fields are already certified by standards including traceability, and the Coffee-Cocoa Board in Côte d’Ivoire has georeferenced 993,031 cocoa farmers.

APA

ClientEarth (2022). Getting to “deforestation-free”. https://www.clientearth.org/media/mdzplo2q/getting-to-deforestation-free_clarifying-the-traceability-requirements-in-the-eu-deforestation-regulation_clientearth.pdf

Chicago

ClientEarth. Getting to “deforestation-free”. 2022. https://www.clientearth.org/media/mdzplo2q/getting-to-deforestation-free_clarifying-the-traceability-requirements-in-the-eu-deforestation-regulation_clientearth.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Getting to “deforestation-free” |date=June 2022 |url=https://www.clientearth.org/media/mdzplo2q/getting-to-deforestation-free_clarifying-the-traceability-requirements-in-the-eu-deforestation-regulation_clientearth.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2022getting, author = {{ClientEarth}}, title = {{Getting to “deforestation-free”}}, institution = {ClientEarth}, year = {2022}, month = jun, url = {https://www.clientearth.org/media/mdzplo2q/getting-to-deforestation-free_clarifying-the-traceability-requirements-in-the-eu-deforestation-regulation_clientearth.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }