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EU’s anti-deforestation bill leaves out critical ecosystems, study shows

cerrado grasslands

1. Because much of the Cerrado’s landscape doesn’t fall under the FAO definition of a forest, it would not be protected by the newly proposed EU deforestation legislation. Image by Sarah Sax.

  • New regulation proposed by the European Commission aims to reduce the import of commodities that cause deforestation and forest degradation abroad.
  • But according to a report commissioned by the EU Greens parliament members, the narrow definition of forest and deforestation in the revised legislation would not protect ecosystems in South America where EU demand for commodities such as soy and beef create high deforestation risk.
  • Soy production is not only destroying native vegetation, but also threatens the livelihoods of hundreds of Indigenous peoples and traditional communities in the Cerrado and Chaco biomes, made of grasslands, savannas and dry forests stretching down the center of South America.
  • Broadening the definition of forest to include other types of wooded land, or adopting a definition based on native vegetation rather than forest, would protect much more of the Cerrado and the Chaco, and be much more effective at tackling deforestation, the report says.

On May 11 this year,  dozens of activists with Greenpeace Netherland blocked a ship carrying 60,000 metric tons of soy from Brazil to the Netherlands. Among the protesters was Alberto Terena, a leader of the Indigenous Terena People’s Council in the state of Mato Grosso do Sul. The Terena live on the border between Brazil and Paraguay, where the Gran Chaco, South America’s second-largest forest, and the Cerrado, the world’s most species-rich savanna, meet.

“Europe shares responsibility for the destruction of our homes,” Alberto Terena said in a statement. “We call on ministers to seize this opportunity, not only to ensure Indigenous people’s rights, but also for the future of the planet. The production of feed for your industrial animals and the beef that is imported should no longer mean our suffering.”

What’s in a word

As the world’s third-largest importer of agricultural commodities linked to tropical deforestation and climate change, such as soy, beef and palm oil, the EU has recognized its outsized environmental footprint abroad. The bloc has been taking steps to tackle that, in line with its Paris Agreement and European Green Deal commitments, including last November, when it proposed new legislation to restrict imports of commodities linked to deforestation. Greenpeace’s protest centered around the idea that the EU’s current draft regulation is much too weak and won’t protect some of the biomes most affected by the rapid expansion of soy farming and cattle ranching, like the Cerrado and Chaco.

Soy and Chaco forest in Bolivia. Photo by Rhett A. Butler

Now, a new has assessed just how much land could be left unprotected if the EU draft goes into law as it stands. The draft uses the U.N. Food and Agriculture Organization’s (FAO) definition of a forest, which is an area larger than 0.5 hectares (1.2 acres) with trees taller than 5 meters (16 feet) and a canopy cover greater than 10%.

But this definition leaves out large swaths of land where soy and cattle expansion is actually occurring, especially the Cerrado and Chaco biomes, which are made up of a mosaic of forests, grasslands, savanna and other types of ecosystems. The report, commissioned by the Greens/EFA bloc in the European Parliament, found that in its current form, the regulation would leave unprotected three-quarters of the Cerrado (79 million hectares, or 195 million acres) and a third of the Gran Chaco (32 million hectares, or 79 million acres). That represents an area larger than France and Spain combined, in the biomes where the EU’s environmental footprint in South America is the greatest.

“If savannas, wetlands and grasslands remain outside the scope of the legislation, the new EU law could in fact increase the already high pressures on natural ecosystems, undermining the EU’s global biodiversity objectives,” Marie Toussaint, a Greens/EFA MEP for France, told Mongabay. “In the face of the biodiversity emergency, the EU must protect all the ecosystems threatened by our consumption patterns, which are ravaging the planet.”

Regulate conversion, not just deforestation

Both the Cerrado and the Gran Chaco have come under increasing threat in recent decades, driven largely by soy farming. The Cerrado has seen around half of its native vegetation cleared for agriculture, a rate higher than the Amazon. According to the report, the majority of the EU’s soy-related deforestation risk, and more than a third of its beef-related deforestation risk, is concentrated in the Cerrado alone, a biodiversity hotspot that’s particularly vulnerable to expansion because of how much land is suitable for agricultural expansion, and how little of the biome is protected. The Gran Chaco has seen an estimated 20% of its native vegetation cleared, while recording one of the highest deforestation rates in the world.

“The EU knows its main deforestation risk comes mainly from the Cerrado and Chaco and if this policy is meant to address this risk, it needs to expand that definition,” said Helen Bellfield, deputy director of Trase. Ultimately, if the EU fails to recognize where its supply chain is having the biggest impact, she added, then it will fundamentally undermine its policy objectives.

The Cerrado and the Chaco are also home to thousands of Indigenous and traditional peoples and communities, many living on lands not formally recognized or still in the process of being formally titled. The rapid destruction of the Cerrado’s native vegetation for soy and pasture has also sparked land conflicts with traditional communities, many of whom don’t exist on official government maps and don’t formally own the collective lands they use. More than 40% of rural land conflicts in Brazil between 2003 and 2018 took place in the Cerrado, although the region accounts for only a fifth of Brazil’s total area.

The Cerrado is home to hundreds of traditional peoples and communities, like the 400,000 coconut breakers who live from the babassu coconut tree that grows in the Cerrado. Image by Sarah Sax.

By using a narrow definition of forests, the EU regulation is likely to shift even more pressure onto the already threatened Cerrado and Chaco biomes, according to Tobias Kuemmerle, head of the Conservation Biogeography Lab at Humboldt University in Berlin.

“We know much less about dry forests and savannas than about rainforests, because they remain poorly studied,” Kuemmerle told Mongabay. “This means we are losing a lot [of information] before we fully understand it — and we often wrongfully render savannas and dry forests as ‘less valuable’ just because they are less studied.”

For example, researchers recently found that all global maps measuring carbon have massively underestimated the carbon stored in the vegetation of the Chaco, which now has one of the highest deforestation rates in the world.

Revising the EU regulation to include “other wooded land” as defined by the FAO would significantly boost the protection of the two biomes, the new report says. It would shrink the total area without protection from 74% to 18% for the Cerrado, and 33% to 24% for the Gran Chaco. However, that would still leave large areas of both biomes vulnerable to EU-driven ecosystem destruction.

Ultimately, the report argues that the draft regulation would be more effective if focused not just on the clearing of forests, but on all native ecosystems.

“Acknowledging that other ecosystems than forests are highly valuable in terms of biodiversity and carbon, and that we should not destroy them on a grand scale, is important,” said Kuemmerle, who was not involved in the Trase/Global Canopy report. “In my view, we should adopt a strict ‘no conversion of natural areas’ policy.”

Matthew Spencer, global director for landscapes at IDH–The Sustainable Trade Initiative, welcomed the report for “highlighting the importance of extending sustainable supply chain efforts to all ecosystems,” but noted in an email to Mongabay that it “assumes that EU traceability requirements will have leverage on soy and beef farming in South America.” According to Spencer, traceability requirements will be much more effective if they focus on reducing and stopping deforestation and on the clearing of all native ecosystems, not just on the EU supply chain.

While the proposal could be up for vote in the European Parliament as early as September, discussions over amendments go beyond how to define forests. Other areas in need of improving include traceability and legality requirements, the rights of Indigenous peoples and traditional communities, and deadlines for stopping deforestation.


Pötzschner, F., Baumann, M., Gasparri, N. I., Conti, G., Loto, D., Piquer-Rodríguez, M., & Kuemmerle, T. (2022). Ecoregion-wide, multi-sensor biomass mapping highlights a major underestimation of dry forests carbon stocks. Remote Sensing of Environment269, 112849. doi:10.1016/j.rse.2021.112849

Banner image: Because much of the Cerrado’s landscape doesn’t fall under the FAO definition of a forest, it would not be protected by the newly proposed EU deforestation legislation. Image by Sarah Sax.