NGO RECOMMENDATIONS ON The future EU Regulation to address the forest, ecosystem, and human rights impacts associated with products placed on the EU market

The briefing argues for a mandatory product-based due diligence framework for Forest and Ecosystem Risk Commodities (FERCs) and their derivatives. It recommends that the regulation cover not only forests but all natural ecosystems and human rights violations, specifically the rights of Indigenous Peoples and local communities. The authors call for equivalent obligations for financial institutions, a robust enforcement mechanism including criminal penalties and access to EU courts for harmed third parties, and accompanying measures to support producer countries and reform EU consumption patterns.

• The proposed EU Regulation should cover a broad range of 'Forest and Ecosystem Risk Commodities' (FERCs) and any products derived from them, including at minimum livestock products (beef, leather, poultry), soy, palm oil, timber, cocoa, coffee, rubber, and maize.
• The scope of the regulation must extend beyond forests to include the conversion and degradation of other natural ecosystems, such as savannahs, wetlands, peatlands, grasslands, mangroves, or riparian buffers, to prevent the displacement of land conversion.
• The regulation must incorporate human rights safeguards, specifically requiring that operators ensure the respect of customary tenure rights and obtain the Free, Prior and Informed Consent (FPIC) of Indigenous Peoples and local communities (IPLCs).
• Operators should be required to perform comprehensive due diligence to ensure there is 'no more than a negligible risk' that their products are linked to targeted negative impacts, including mapping the entire supply chain and using satellite data for production areas.
• Financial institutions operating in the EU should face equivalent due diligence obligations to ensure their services do not finance companies contributing to ecosystem destruction or human rights violations, noting that EU banks like Santander and Deutsche Bank provided €7 billion to harmful agribusinesses between 2013 and 2019.
• A robust enforcement framework is necessary, featuring dissuasive penalties—including criminal penalties and fines based on a percentage of annual company turnover—and the ability for harmed third parties to seek redress in EU courts.
• The EU should implement accompanying measures, including technical and financial support for IPLCs and smallholders in producer countries and domestic policy reforms to reduce the consumption of meat and dairy products.

APA

ClientEarth (2021). NGO RECOMMENDATIONS ON The future EU Regulation to address the forest, ecosystem, and human rights impacts associated with products placed on the EU market. https://www.clientearth.org/media/ylrd34wj/ngo_recommendations_eu_regulation_to_address_forest_and_human_rights_impacts.pdf

Chicago

ClientEarth. NGO RECOMMENDATIONS ON The future EU Regulation to address the forest, ecosystem, and human rights impacts associated with products placed on the EU market. 2021. https://www.clientearth.org/media/ylrd34wj/ngo_recommendations_eu_regulation_to_address_forest_and_human_rights_impacts.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=NGO RECOMMENDATIONS ON The future EU Regulation to address the forest, ecosystem, and human rights impacts associated with products placed on the EU market |date=April 2021 |url=https://www.clientearth.org/media/ylrd34wj/ngo_recommendations_eu_regulation_to_address_forest_and_human_rights_impacts.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2021ngo, author = {{ClientEarth}}, title = {{NGO RECOMMENDATIONS ON The future EU Regulation to address the forest, ecosystem, and human rights impacts associated with products placed on the EU market}}, institution = {ClientEarth}, year = {2021}, month = apr, url = {https://www.clientearth.org/media/ylrd34wj/ngo_recommendations_eu_regulation_to_address_forest_and_human_rights_impacts.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }