ISEAL’s support and recommendations for the EU’s proposed regulation to stop deforestation

The European Commission published its Proposal for a Regulation on Deforestation-free Products in November. ISEAL welcomes this landmark initiative, which has the potential to be a groundbreaking regulatory effort to ensure companies take concrete steps to address global deforestation.

Certification systems help to build sustainable supply chains. Their impact increases when they are underpinned by a mandatory legal floor. Legislation that effectively defines responsibilities and minimum sustainability expectations for supply chain actors can be a powerful driver of change. In this light, the Commission’s proposal is a welcome milestone.

Driving greater impacts

In reaction to the proposal, ISEAL has published a position paper that recommends six areas of adjustment to the legislation to better prevent and mitigate global deforestation. These include improving implementation of the due diligence process, and how we define impactful corporate due diligence that builds on existing partnerships at producer and production country level. 

In summary, the paper highlights that:

  • the Commission’s proposal only prescribes minimum requirements. Companies should adhere to best practice, exceed legal requirements, and take a holistic approach to tackling deforestation 
  • robust and verified information should be used to determine that products have been produced in compliance 
  • The Commission needs to specify minimum requirements for certification and other third party schemes before they can be used within a due diligence process
  • operators should invest in substantive and impactful risk mitigation measures, through capacity building and other actions 
  • An impact assessment on smallholders and vulnerable communities should be carried out before the regulation enters into force
  • supply-side investment and sector-wide partnerships and programmes need to be part of the smart-mix of interventions to combat global deforestation.

If we want to see an impactful regulation that ensures EU companies can build on existing best practice and effectively address deforestation at a global level these points need to be addressed.

The role of certification

We believe a strong integration between company due diligence processes and third party initiatives, such as certification systems or other similar tools, is key to ensuring the effective and impactful implementation of the proposed regulation. 

Certification systems and similar tools help address the challenging aspects identified in the ISEAL position paper, help streamline company actions and investments, and ensure a producer-oriented approach in tackling deforestation. They do not absolve operators from their duties and responsibility under the due diligence obligations that would be introduced. 

Certification systems are producer-oriented tools that build on a multi-stakeholder consensus to achieve environmental, social and economic sustainability impact. There is no one solution to the big challenges such as deforestation. A range of approaches is needed, working together to maximise the collective strength. In this way, credible certification systems and similar tools can support the implementation of the new EU regulation in a variety of ways and enhance its impact.