IATP submitted the following letter to the U.S. State Department on December 2, 2022 in response to the request for stakeholder input on options for combating international deforestation associated with commodities.
The Institute for Agriculture and Trade Policy (IATP) is pleased to comment on this Request for Stakeholder Input about Options for Combating International Deforestation associated with Commodities. IATP is a 35-year-old Minnesota-based 501(c)(3) non-profit organization, with offices in Washington, D.C. and Berlin, Germany. IATP’s mission is to work locally and globally at the intersection of policy and practice to ensure fair and sustainable food, farm and trade systems.
Since its formation during the farm crisis in the 1980s, IATP has analyzed how trade regimes impact farmers, rural communities and the environment in the U.S. and internationally. As part of this work, we have tracked closely global agriculture commodity production and the companies that dominate this sector. Over the last decade, we have deepened our focus on global meat companies, including in areas of the world dealing with increased deforestation,1 and the rising (and significant) climate footprint of those companies.2
The U.S. government has an important role in supporting efforts to stop deforestation internationally and a special responsibility as a major importer of deforestation-linked commodities to work with both importing and exporting countries on solutions. Not only does stopping deforestation reduce carbon dioxide emissions released from forests and the further carbon sequestration that could come from intact forests, it also can help curb the steady rise of agriculture-related greenhouse gas emissions (methane and nitrous oxide) tied to expanded land use. This is particularly true for rising emissions from the expansion of industrial animal agriculture systems worldwide, which rely on the heavy use of nitrogen fertilizer for animal feed.
The European Parliament, recognizing its responsibility for global deforestation, moved forward in September to approve a policy requiring importing companies to verify whether products are produced in deforested areas — including those that were cleared legally.3 The regulation would ban certain commodities (beef, cocoa, soy, wood, coffee, palm oil) unless they were deforestation-free, produced in accordance with the relevant legislation in the country of production and covered by a due diligence statement. Other countries like the United Kingdom are similarly taking action to address imports of deforestation-linked commodities. We would encourage the U.S. government to work closely with the EU and other importing countries, alongside developing countries in aligning new rules for deforestation-free commodities. All countries should consider whether new deforestation policy frameworks should go beyond forests to include fragile ecosystems such as Brazil’s Cerrado savanna and peatlands in Southeast Asia.
Governments, Not the Private Sector, Must Lead in Addressing Agriculture Commodity Driven Deforestation
It is well recognized that agriculture production expansion is the biggest driver of deforestation,4 contributing to more than 90% of tropical deforestation worldwide today.5 The commodities produced through that agriculture-linked deforestation often enter global supply chains, largely controlled by global companies with significant economic and political power. At COP26, 10 of the biggest agriculture commodity traders committed “to halting forest loss associated with agricultural commodity production and trade.”6 But many of these same companies have made previous commitments, including the United Nations’ New York Declaration on Forests, to halt deforestation in their supply chains going back more than a decade, only to retract those commitments later.7 Because of this track record of backsliding in the private sector on deforestation-related commitments, it is essential that governments set clear expectations for the marketplace through new rules to address commodity-driven deforestation, with strong regulatory guidelines, requirements for greater transparency and an enforcement system with established penalties. If U.S. policies on this issue are carefully crafted, they can be fully compliant with World Trade Organization rules.
Beyond Trade, Aiding a Transition
Trade on its own is a blunt instrument to stop global deforestation. A whole-of-government approach should also include targeted aid and incentives to help developing countries protect their forests and transition toward more agroecological, sustainable agricultural production and rural economies. Developing countries have raised important questions, grounded in equity, about the European Union and U.K.’s deforestation rules. For example, Brazil has raised complaints about U.K. proposals to block companies from using products from deforested land, threatening a WTO challenge,8 claiming that such rules give advantages to developed countries where much of their forests have already been deforested and discriminate against tropical, developing countries. Developing countries have criticized the EU’s deforestation regulation as protectionist and punitive against developing countries, claiming that the regulation disregards local conditions and legislation to protect natural resources, and would require costly traceability requirements. In response to some of the criticisms, the EU has created a fund to help trading partners respond to the new regulation.9
It is important that the U.S. government work with countries battling deforestation to help those economies transition away from a deforestation-driven economy, and not take an exclusively punitive strategy.
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