Was it produced legally? Due diligence on legal compliance – Indonesia

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The document examines the application of the EU Deforestation Regulation's (EUDR) legality requirement to the Indonesian palm oil sector. It highlights a complex, decentralized legal framework where national laws are often poorly enforced at sub-national levels. Key systemic risks include widespread failure to obtain mandatory Indonesia Sustainable Palm Oil (ISPO) certification, pervasive corruption in permitting, illegal plantation establishment in forest zones, and significant violations of Indigenous land rights and labour standards. The report concludes that EU companies cannot rely solely on official documentation or third-party certificates for due diligence due to these systemic irregularities.

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  • Non-compliance with the mandatory Indonesia Sustainable Palm Oil (ISPO) certification is systemic, with reports suggesting that roughly half of Indonesia's productive palm oil plantations lack the required certification.
  • A 2019 audit by the National Audit Board (BPK) found that approximately 81% of oil palm plantations were non-compliant with regulatory requirements, including issues with business permits (Hak Guna Usaha), failure to develop plasma areas, and operation within protected areas.
  • Illegal expansion into forest zones is a major issue; estimates from 2019 suggest that between 20% and 54% of official palm oil plantation areas were illegally located in forest areas without necessary permits.

Cite the original document

APA
Rice, M., & Godts, R. (2025). Was it produced legally? Due diligence on legal compliance – Indonesia. ClientEarth. https://www.clientearth.org/media/hgvgx5wo/was-it-produced-legally_indonesia_clientearth_april-2025.pdf
Chicago
Rice, Michael, and Raphaëlle Godts. Was it produced legally? Due diligence on legal compliance – Indonesia. ClientEarth, 2025. https://www.clientearth.org/media/hgvgx5wo/was-it-produced-legally_indonesia_clientearth_april-2025.pdf.
Wikipedia
{{cite report |last1=Rice |first1=Michael |last2=Godts |first2=Raphaëlle |title=Was it produced legally? Due diligence on legal compliance – Indonesia |publisher=ClientEarth |date=April 2025 |url=https://www.clientearth.org/media/hgvgx5wo/was-it-produced-legally_indonesia_clientearth_april-2025.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{rice2025was, author = {Rice, Michael and Godts, Raphaëlle}, title = {{Was it produced legally? Due diligence on legal compliance – Indonesia}}, institution = {ClientEarth}, year = {2025}, month = apr, url = {https://www.clientearth.org/media/hgvgx5wo/was-it-produced-legally_indonesia_clientearth_april-2025.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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