Skills Training to Reduce Deforestation

The EU Deforestation Directive 2023/1115 has the potential to force the adoption of the circular economy in ways we have yet to imagine. Although the technical and legal details are laid out in the Directive to reduce deforestation, it will, inevitably, open the door to improvements in agricultural yields, water management, new material innovation, reprocessing technologies, collection systems, the Circular Rs and waste management.

The days when we cleared land to satisfy our needs is slowly coming to an end. We are entering a phase where not only must we extract the maximum value from the land already under cultivation, we must also share the planet with all the other living creatures. Humanity has made a promise to do this via biodiversity commitments. As man has been the centre of the universe since he/she first stood on two legs and walked, this may be the hardest task yet.

Here are the products under scope in the EU Deforestation Directive

Basic Skills Required to Meet the EU Deforestation Requirements

• Supply Chain Mapping and Traceability

Why are supply chain mapping and traceability so crucial for EUDR compliance? 

1. EUDR demands proof: The regulation requires companies to demonstrate the deforestation-free origins of traded commodities, from farm to fork. Without robust mapping and traceability, this becomes an impossible feat. 
2. Building trust: Consumers are increasingly conscious of deforestation and ethical sourcing. Transparent traceability builds trust and enhances your brand reputation. 
3. Risk mitigation: Mapping your supply chain allows you to identify and address deforestation hotspots and human rights risks, minimizing potential violations and associated penalties. 
4. Continuous improvement: Traceability data provides valuable insights into your supply chain efficiency and sustainability performance, enabling you to identify areas for improvement and optimize your sourcing practices. 

• Geolocation Requirements

Geolocation within the EUDR context refers to the precise geographic coordinates identifying the exact location where commodities are produced.

This data is crucial as it allows regulators and companies to trace products back to their origins, ensuring they are not sourced from areas subject to illegal deforestation.

Geolocation data includes latitude and longitude coordinates, plot boundaries, and any relevant geographic identifiers. Geolocation data is typically provided as polygons that mark the exact boundaries of a plot of land.

The dotted yellow polygon marks a rubber plantation

For plots of land of more than 4 hectares, the geolocation must be provided using polygons, meaning latitude and longitude points of six decimal digits to describe the perimeter of each plot of land.

For plots of land under 4 hectares, operators (and traders who are not SMEs) can use a polygon or a single point of latitude and longitude of six decimal digits to provide geolocation. 

• Conducting a Risk Assessment

Risk levels are determined by various factors, such as the presence of forests and deforestation, conflicts over land rights with indigenous communities, mixing and circumvention, supply chain complexity, and even socio-political aspects, including corruption and lack of transparency. This comprehensive analysis must be updated at least annually, serving as a living document that evolves based on ever-changing circumstances.

As a general rule, operators (and traders who are not SMEs) will have to set up and maintain a Due Diligence System, which consists of three steps. 

As step one, they have to collect information such as the commodity or product which they intend to place (or make available in case of non-SME traders) on the market or export. This includes, among other things, respective quantity, supplier, country of production, and evidence of legal harvest. Refer to Article 9 of the EUDR Directive.

In step two, companies have to feed the information gathered under the first step into the risk assessment pillar of their Due Diligence Systems to verify and evaluate the risk of non-compliant products entering the supply chain. Operators need to demonstrate how the information gathered was checked against the risk assessment criteria and how they determined the risk. Follow the criteria described in Article 10 of the EUDR Directive.

In step three, they have to take adequate and proportionate mitigation measures in case they find under step two more than a negligible risk of non-compliance in order to make sure that the risk becomes negligible. These measures need to be documented. Follow the criteria described in Article 11 of the EUDR Directive.

Conclusion

The EU Deforestation Directive will have a much greater impact than just the mechanics of the law. There are approximately more than 2,700 waste-to-energy plants around the world. Incineration perpetuates the need to continually extract primary raw materials from nature, it negates our ability to reduce waste, improve recycling rates and embed the development of a secondary raw materials industry into our society. Waste-to-energy is not renewable energy.

The truth is we cannot afford to burn end-of-use-cycle items when we should be valuing natural resources that give us the lifestyle many of us enjoy today. It is impossible to transition to a sustainable world unless we recognise this fact. For more than 60 years we participated in recycling programs that did not equate to 'saving the environment' yet we still persist with this myth.

The rest of the world will end up emulating the EU Deforestation Directive because it will need to. Not to save the environment but to meet our biodiversity commitments and begin the transition to material innovation and vastly different collection systems than what we have today.

Karl Marx once stated, "Religion is the sigh of the oppressed creature, the heart of a heartless world, and the soul of soulless conditions. It is the opium of the people." We have traded religion as the opium of the people for our middle-class lifestyles. Political systems are dependent on this new opium. The world is simply not big enough to accommodate all the competing ideologies for a sustainable world that include recycling, incineration, biodiversity loss and deforestation.

Something has to give...

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Ms Adrienna Zsakay is the Founder and CEO of Circular Economy Asia Inc., and this article represents her opinions on the circular economy. Circular World Pick of the Week is brought to you by Circular World™ Media — a brand owned by Circular Economy Asia Inc.

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References

'Detangling the EU Deforestation Regulation' published by the World Business Council for Sustainable Development, 19 June 2024

'5 Essential Steps for EUDR Compliance' published by Trace X, 09 February 2024

'A Comprehensive Guide to Mastering EUDR Geolocation Data Collection' - Understanding Geolocations' published by Live EO, 18 July 2024

'Understanding Compliance Risk Assessment for EUDR' published by Trace X, 31 July 2024

'What are my obligations as an EU operator?' published by Green Business, European Commission