2024 was the worst year in decades for tropical deforestation, according to Global Forest Watch reports. South America, on which the UK depends for animal feed, experienced the highest rates; in West Africa, huge spikes in deforestation linked to cocoa was followed by droughts; in the UK, unusually heavy rain significantly reduced wheat yields.
Daily, it seems, our fraught geopolitical context highlights the good sense of the recent EU/UK realignment ranging from defence and security to youth experience and passport checks. With their rapprochement now agreed, there is an opportunity to mutually reinforce their legislative frameworks for protecting forests, and to maximise the international impact of commitments to halt and reverse forest loss by 2030. Trade in forest-risk commodities, bioenergy and support to Indigenous Peoples and Local Communities are areas where a united front is particularly promising.
EUDR and Schedule 17
Due diligence legislation for forest-risk commodities should aim to synergise efforts to rein in forest destruction linked to domestic consumption. Whilst the EU is moving its Deforestation Regulation (the EUDR) forward, the UK has dragged its feet for more than three years on publishing implementing legislation under its 2021 Environment Act (“Schedule 17”).
While UK businesses have pioneered voluntary initiatives to support more sustainable production globally, they are insufficient and increasingly under threat. This includes the 18-year old Amazon Soy Moratorium, which is now being rejected by soy suppliers seeking to misuse Brazilian subsidies at the expense of natural resources, and opening up global markets to soy grown in newly deforested areas. Without more governmental support for market action to protect this resource from complex commercial supply chains, our food systems will come under increasing risk of disruption by climatic events and loss of ecosystems services with estimated gross output loss on oilseed sector of up to $220.5 billion in Brazil (World Bank Document).
There is therefore now an opportunity to maximise synergies to benefit forests. Schedule 17 should join the EUDR in mentioning the need to comply with “relevant local laws”, including human rights, land rights, and Free, Prior and Informed Consent (FPIC). It also makes sense for both laws to cover similar commodities. The most recent UK proposal did not cover EUDR commodities coffee and rubber. UK due diligence requirements should mirror EU obligations: tracing commodities to the point of harvest; and requiring that acceptable deforestation risk in due diligence statements be ‘negligible’.
In turn, Schedule 17 could bridge shortcomings of the EUDR, notably by including all biomes at risk of conversion, even those not defined as ‘forests’ by the FAO. All major supply chain actors operating in South America now cover this in their under science based commitments in recognition of the bulk of the land use change emissions from conversion of non tropical forest ecosystems for commodities from this region. Eventually, the EUDR should also be extended to conversion of Other Wooded Lands (OWLs), as soy actors covering 60% of the UK market have already committed to do in specific agreements (see also FW 304).
The publication of Schedule 17 and its alignment with the EUDR are not only crucial for forests, they are also necessary for trade – every year, the UK exports an average of £5.2 billion in EUDR-covered goods to the EU (Eurostat data). Companies exporting these products to the EU will need to undertake supply chain traceability and confirm that they have been legally harvested.
Robust enforcement of both laws will be crucial, and the EU and UK could mutually bolster efforts to investigate due diligence processes effectively, exchanging information about non-compliant organisations and those who falsely report, and welcoming independent third-party scrutiny.
Bioenergy subsidies
Aligning phase-out of subsidies to bioenergy offers another opportunity for the EU and UK to pull each other upward, making bioenergy more genuinely sustainable.
The EU’s bioenergy requirements remain far from adequate, but they go further than the UK in ruling out burning types of biomass (such as industrial-grade roundwood). Conversely, the UK’s ban on any biomass from old-growth or primary forests and its caps on bioenergy power generation go further than the EU: the UK announced that, from 2027, power generation from large-scale bioenergy power plants will be halved, and as a result subsidies will roughly decrease by half. The EU is also phasing out power production from electricity-only plants, albeit with large loopholes and no caps.
Worryingly, both the EU and the UK fail to recognise a fundamental problem: forest biomass is not carbon neutral, and should not be counted as such, as is done currently. Moreover, both the UK and EU are looking towards bioenergy with carbon capture and storage (BECCS) and other carbon removal ‘silver bullets’ as solutions to the climate crisis – dangerous propositions that fly in the face of climate reality and the forest damage they cause, as well as the precautionary principle. Such technologies have not been proven at scale or in time-frames appropriate to the climate crisis.
Both the EU and UK should instead concentrate on proven methods that yield immediate rewards, such as forest restoration and decreased harvesting.
In the lead-up to the UN Framework Convention on Climate Change conference in Belém (COP30), the EU and UK should lead by example and meet historic obligations, including by swiftly publishing (for the UK) and safeguarding (for the EU) ambitious due diligence legislation for Forest Risk Commodities. They should also significantly increasing climate finance for climate-vulnerable nations, directly supporting Indigenous Peoples and Local Communities (as voiced by Brazilian Indigenous hosts) and supporting nature’s role in climate resilience by increasing finance for conservation and restoration (see TFFF).
Together, the EU and UK have the opportunity to insist on a more positive climate and human rights narrative at a time when the United States has seemingly abandoned all such ambition.
A modified version of this text was originally published in Fern’s ForestWatch – to sign up click here
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