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The document assesses the UK's proposed law to minimise deforestation linked to 'forest risk commodities', arguing that its reliance on 'relevant local laws' creates a loophole that would allow commodities from Brazil to enter the UK market even if they result from legalised deforestation. It details several Brazilian legislative proposals (such as PL 2633/2020 and PL 490/2007) that aim to legalise land grabbing and restrict Indigenous land rights. ClientEarth recommends that the UK adopt an objective standard covering all deforestation, mandate free, prior and informed consent (FPIC) for Indigenous Peoples, and explicitly include cattle, soy, and non-agricultural commodities like mining and oil and gas in the framework.

The document is an appendix of consulted legislation for a report on forest restoration in the Amazon. It catalogs federal laws and specific state-level legal frameworks from Acre, Amapá, Amazonas, Mato Grosso, Pará, and Rondônia, and Roraima. The listed legislation covers a wide range of environmental governance topics, including the Forest Code, REDD+ mechanisms, Environmental Regularization Programs (PRA), and state-specific policies on bioeconomy, agroecology, and payment for environmental services.

The document analyzes a shift in Amazon deforestation from large-scale to small-scale clearings between the mid-2000s and early 2010s. It finds that while conservation policies introduced in 2004 successfully reduced large-scale deforestation, they created a technical gap where clearings of 25 hectares or less go mostly undetected. Using data from Mato Grosso and Pará, the research shows that landholders have adapted their practices to elude monitoring, with smallholders in Pará emerging as primary agents of clearing. The brief recommends enhancing remote sensing technology and tailoring policies to local regional characteristics.

Between 2004 and 2012, the annual deforestation rate in the Brazilian Amazon fell from 27,000 km² to 4,500 km², but the composition of this deforestation shifted. While large-scale clearing decreased due to public policies, deforestation in small clearings (under 25 hectares) grew from representing one-quarter of the total in 2004 to more than half by 2012. The document highlights that current satellite monitoring systems cannot detect clearings smaller than 25 hectares, allowing many actors—particularly small landowners in Pará and medium-to-large landowners in Mato Grosso—to evade detection. The authors recommend tailoring policies to regional differences and improving remote sensing technology to detect small-scale deforestation.

The document argues that the Brazilian Amazon's diverse ecological and productive capacities allow for a strategic reordering of land use, where agricultural productivity is increased in degraded areas while high-carbon-capture areas are restored. It proposes the Reversing Deforestation Mechanism (RDM), a jurisdictional payment-for-results system that remunerates net carbon removals from forest restoration. The report estimates that natural regeneration in deforested areas could capture up to 26 GtCO₂, with the RDM potentially generating US$ 784 billion over 30 years at a price of US$ 50 per ton of CO₂. This mechanism is presented as complementary to JREDD+ (focused on reducing deforestation) and the Tropical Forest Forever Facility (TFFF, focused on maintaining standing forests), together forming a financial architecture to support Brazil's Nationally Determined Contributions (NDC) and the transition to a low-carbon economy.

Brazilian conservation policies have successfully reduced overall deforestation rates, but the methods of deforestation have evolved. To avoid satellite detection, there has been a shift from large clearings to smaller clearings (under 25 hectares), with this trend varying by state.

The report analyzes how state policies in the Brazilian Amazon facilitate or hinder forest restoration. It finds that while states have been pioneers in REDD+ and PSA and are essential for implementing the Forest Code via CAR and PRA, significant gaps remain. These include a lack of integrated governance, insufficient incentives for voluntary restoration, and bureaucratic barriers to native species silviculture. Pará is highlighted as the most advanced state, being the only one with a comprehensive State Native Vegetation Recovery Plan (PRVN-PA) and a mechanism for restoration concessions on public lands.

The report identifies a significant opportunity for carbon capture in the Brazilian Amazon, estimating that natural regeneration of deforested areas could sequester up to 26 GtCO₂. It proposes the Reversing Deforestation Mechanism (RDM), a jurisdictional results-based payment system, which could mobilize up to US$ 784 billion over 30 years at a carbon price of US$ 50 per ton. The RDM is presented as a complementary tool alongside JREDD+ (focused on reducing deforestation) and the Tropical Forest Forever Facility (TFFF, focused on conserving standing forests) to help Brazil meet its NDC targets and transition to a low-carbon economy.

Brazilian conservation policies led to an 80% drop in deforestation rates between 2002 and 2012. However, the document notes that deforestation practices have evolved to avoid detection, with an increase in 'small clearings' (under 25 hectares) that monitoring satellites cannot detect. These practices vary by region, specifically citing differences between Mato Grosso and Pará.

The report alleges that Brookfield Asset Management oversaw the deforestation of approximately 9,000 hectares of the Brazilian Cerrado between 2012 and 2021 across eight farms, subsequently selling these assets in a 'slash and sell' strategy. It further details a case where a Brookfield-controlled firm was fined R$800,000 for slave labour offences at Fazenda Colorado and an attempt to evict the Kayabí Indigenous community from ancestral lands in the Amazon via the company Agropecuaria Vale do Ximari. The document highlights a contradiction between these actions and the public roles of Brookfield Chair Mark Carney, a co-founder of the Glasgow Financial Alliance for Net Zero (GFANZ), and the firm's ESG policies. It argues that voluntary initiatives like GFANZ are insufficient and calls for mandatory government legislation on environmental and human rights due diligence for the financial sector.

Global Witness reports that industrial agriculture is accelerating biodiversity loss in Brazil, with over 27 million hectares of jaguar habitat converted to agricultural land in Mato Grosso and Pará as of 2023. The investigation highlights JBS's role, finding that 75% of identified farms in JBS's supply chain overlapping jaguar territory in these states violated environmental laws between 2018 and 2023. The report specifically identifies the Canoeiro farm as having cleared over 1,200 hectares of protected jaguar territory between 2013 and 2023, using 'cattle laundering' to enter JBS's supply chain. Global Witness argues that stronger supply chain and finance regulations are necessary to prevent the extinction of keystone species and meet global climate goals by 2030.

The document details the application of MODIS satellite imagery and automated algorithms to track land use dynamics in the La Plata River Basin. It focuses on the transition of agricultural frontiers—from deforestation to intensification—and the use of remote sensing to estimate evapotranspiration and water balance. A case study in Mato Grosso demonstrates how these tools can map the expansion of soybean and sugarcane, the adoption of double-cropping systems, and the resulting impacts on natural biomes like the Cerrado and Amazon forest.

The report by Mighty Earth alleges that Carrefour, as a leader in Brazilian retail, is linked to significant deforestation in the Amazon and Cerrado. It highlights a heavy reliance on JBS for beef and Bunge for soy, both of which are identified as major drivers of deforestation. The report estimates Carrefour's potential responsibility for Amazon deforestation at 4.4% and documents specific links to illegal land clearing in indigenous territories.

Mighty Earth's Deforestation Tracker identifies significant land clearance linked to major Brazilian agribusiness traders, specifically highlighting JBS, Cargill, and Bunge as poor performers. The report details how these companies supply supermarkets in the US, UK, Germany, France, and the Netherlands, and urges retailers to implement strict no-deforestation policies and shift sourcing to better-performing traders.

The report reveals that BNP Paribas, Crédit Agricole, Société Générale, and BPCE provided $10 billion in financing to Bunge and Cargill between January 2024 and September 2025, despite the traders' exposure to deforestation risks in Brazil. Analysis shows that Bunge and Cargill are linked to 11,800 hectares of deforestation in the Amazon and 91,000 hectares in the Cerrado during this period. The document criticizes the deforestation policies of the involved banks as insufficient, lacking clear objectives, and opaque in their implementation.

The document argues that REDD+ programs must integrate legal, financial, and reputational accountability tools to ensure governments meet social and environmental objectives beyond greenhouse gas emission reductions. Drawing on case studies from Brazil and Indonesia, it identifies three primary functions of accountability tools: facilitating negotiations for reform, protecting people and the environment during policy implementation, and enabling the enforcement of agreed rules. The author suggests that REDD+ designers should explicitly include civil society in monitoring and oversight roles and build upon existing, effective laws rather than layering new programs over ineffective ones.

The Pantanal is the world's largest wetland, spanning Brazil, Bolivia, and Paraguay, and providing ecosystem services valued at $112 billion. It faces threats from land use changes, upstream pollution, and climate change, which is predicted to make the region hotter and drier. WWF is implementing a 'Trinational Initiative' to promote sustainable infrastructure, expand protected areas, and eradicate deforestation, which has already caused a loss of over 12% of the region's forest cover.

Argentina is uniquely positioned to lead the global market in deforestation and conversion-free (DCF) beef due to its existing national traceability systems and strong market position, particularly with China. By integrating its cattle movement monitoring with the Forest Law's satellite-based Early Warning System, Argentina could provide credible DCF exports. This approach would help the country meet Paris Agreement commitments, attract trade finance from European and Chinese markets, and protect critical ecosystems like the Gran Chaco. While challenges include the lack of price premiums for DCF products and the need for an interoperable data platform, the model offers a scalable alternative to fragmented company-led sustainability commitments.