- With the European Union’s Deforestation Regulation (EUDR) nearing implementation, Mongabay reached out to five of the world’s largest traders to find out how ready the soy sector is. Responses ranged from “no comment” to no reply.
- Despite the silence, experts from trade associations and NGOs say that big soy traders are already operationally prepared to meet EUDR requirements.
- Certification bodies and verification networks, such as ProTerra and VISEC, appear to be playing a key role in helping the soy sector get ready for the EUDR.
- Although experts express optimism about the regulation’s potential positive impacts, they underscore its limitations, particularly the exclusion of non-forest ecosystems, and call for continued vigilance in its implementation and corporate commitments.
As the European Union’s Deforestation Regulation (EUDR) approaches its implementation, companies involved in supply chains for soy and other commodities reaching the EU market will soon have to prove that their products do not come from areas deforested after 2020 and that their operations comply with local environmental and human rights laws. This will be particularly challenging for the soy sector, as soybean production has long been a major driver of deforestation, especially in South America.
Initially scheduled to take effect in December 2024, the EUDR was postponed for a year, with the European Commission recently proposing an additional grace period to give companies more time to prepare.
To find out how ready the soy sector is, Mongabay reached out to five of the world’s largest traders: ADM, AMAGGI, Bunge, Cargill and COFCO International. Responses ranged from “no comment” to no reply.
Despite the silence, experts from trade associations and NGOs say big soy traders are already operationally prepared to meet EUDR requirements.
“The information we have, which they [traders and soy sector associations] usually share with us, is that they are 100% prepared,” Tiago Reis, conservation specialist at WWF-Brazil, told Mongabay in a voice message. “Some even questioned the proposal to extend the [EUDR] deadline, because they had already invested … so they would be ready to comply.”
Data from Global Canopy’s Forest 500 report show that in 2024, nearly half of companies — from producers to retailers with the greatest deforestation-risk exposure — had public deforestation-free commitments for soy trade. This is up from 31% in 2020.
“Forest 500 data does not speak directly to EUDR readiness as the assessments are based only on public disclosures, and companies may engage in compliance preparations that are not publicly reported,” Emma Thomson, Global Canopy’s Forest 500 lead, told Mongabay via email. “However, the published commitments tracked by Forest 500 do indicate that companies increasingly recognise soy deforestation as an issue.”
In addition, big soy traders such as AMAGGI and Cargill have already conducted “dry runs,” or pilot shipments, to test compliance with the regulation, which demonstrate they are “operationally ready,” Thomson added.
Silent preparation
Trading giants such as ADM, AMAGGI, Bunge, Cargill and COFCO dominate global soy flows, most of which is produced in Brazil, the U.S. and Argentina. When Mongabay inquired about their EUDR preparations, all declined to comment or kept silent. Yet their sustainability reports show extensive traceability systems and deforestation-free pledges.
AMAGGI, headquartered in Brazil, said it will engage only at the sector level through Abiove, the national association of vegetable oil industries, and “will not make additional comments beyond what is already published in the company’s most recent Progress Report,” a spokesperson wrote to Mongabay. The company’s 2024 Progress Report indicates that key EUDR due diligence requirements are in place: 100% traceability of direct suppliers in Brazil and 98.8% of soy volumes in the Amazon and Cerrado after 2020 as deforestation- and conversion-free.
Bunge also declined to comment and pointed to its sustainability report. “We’re not able to participate at this time, but we published processes and goals in our sustainability report,” a spokesperson wrote to Mongabay. The report indicates 99% traceability in priority South American regions and 97% of direct-sourced soy purchased in those regions in 2024 as deforestation- and conversion-free.
ADM replied briefly, “We respectfully do not have a comment to offer for this.” Cargill and COFCO, on the other hand, kept silent.
In the latest Forest 500 assessment of corporate commitments, AMAGGI and Bunge achieved above-average scores of 62.5% and 51.1%, respectively. Thomson says this is mainly because both companies “reported key processes that would enable them to implement their deforestation commitments,” including traceability mechanisms to monitor suppliers’ compliance with deforestation and human rights standards, measures to address noncompliance, and active participation in jurisdictional initiatives.
Reis of WWF-Brazil said the Amazon Soy Moratorium, to which several traders are signatories, helped the sector prepare in advance. This 2006 multi-stakeholder agreement, he said, laid the foundation for “social and environmental monitoring of soy production,” including the adoption of traceability and verification mechanisms.
Although voluntary, it has been highly effective in identifying and blocking deforestation from soy sourced in the Brazilian Amazon, Reis added.
Despite moves in the right direction, there’s still room for improvement, Thomson says. She pointed to Trase’s assessment of Brazilian soy production and exports in 2022, the latest data available on its platform, which shows that these big traders are highly exposed to deforestation and conversion of natural vegetation in their soy supply chains outside the Amazon, especially in the Cerrado and Pampas biomes.
Certification and verification
Certification bodies and verification networks appear to be playing a key role in helping the soy sector get ready for the EUDR.
The ProTerra Foundation, for example, which certifies several major soy companies, has updated its standards to align with the EU regulation. According to Emese van Maanen, ProTerra’s managing director, their standards provide a structured approach to assessing and verifying due diligence practices, including traceability and independent third-party audits.
“They are a tool to strengthen and support companies in preparing and implementing a robust, deforestation-free and socially responsible supply chain,” van Maanen told Mongabay via email.
She added that ProTerra’s standards “take a broader approach to sustainability than the EUDR,” covering a wider range of ecosystems, including wetlands and peatlands, and promoting good agricultural practices, such as the responsible use of pesticides.
While van Maanen did not specify which companies have already been certified as EUDR-ready, she pointed to the ProTerra Network Directory, which lists all current certified members — including four of the five soy traders contacted for this story. The managing director also said their standards are voluntary and that the foundation “does not assume responsibility or liability for legal compliance.”
The Round Table on Responsible Soy, despite its leading role in the sector, declined to comment. “We appreciate your interest in our Chain of Custody Standard and our procedures for verifying deforestation- and conversion-free soy. Given that European legislation [EUDR] is continuously evolving, RTRS prefers not to provide specific comments at this time,” a spokesperson wrote to Mongabay.
In Argentina, a multi-stakeholder initiative known as VISEC (Visión Sectorial del Gran Chaco Argentino) is helping companies to trace soy from individual farms in the Gran Chaco region to export ports and to document compliance with the EUDR.
Franco Coiro Di Marco, nature and agriculture stakeholder engagement specialist at The Nature Conservancy and part of VISEC’s Technical Secretariat, explained to Mongabay in an email interview how their verification system works. Once farm polygon coordinates and producer information are uploaded into the system, specialists in satellite imagery analyze them to verify compliance with key EUDR requirements: deforestation-free after December 2020, adherence to national forest laws and no overlap with protected areas.
Next, independent third-party audits are conducted across the supply chain, from factories to ports. “Finally, the company gets a … file with all the geoinformation of the productive units to be uploaded to the EU information system (to create their due diligence statement),” Di Marco said.
Di Marco did not specify which companies VISEC has already verified as EUDR-ready but said that “several companies are already integrated” into their system.
In 2024, VISEC backed three pilot soy shipments from Argentina to Spain, Ireland and France to test EUDR compliance on the ground. They offered several key lessons, Di Marco said, including how to coordinate multiple actors across the soybean supply chain, how to present data in the format required by the EU and the importance of locally calibrated satellite data to avoid “false positives” in deforestation detection.
Yet, Di Marco said the sector still faces significant challenges in meeting EUDR requirements, particularly due to the costs and complexity of gathering the necessary documentation. “It’s not only the deforestation-free condition, there’s a lot of legal aspects to comply with: tax and anticorruption, labor rights, indigenous lands, forest laws, etc.,” he said.
Similarly, van Maanen noted that key sector-wide “difficulties include: Data ownership and availability, Data flow, Additional costs, Complexity for smallholders.”
Not a silver bullet
While companies gear up for compliance, experts weigh in on the limitations of the EUDR and its potential impacts.
According to Thomson of Global Canopy, Forest 500 data show that only 23% of companies assessed for soy in 2024 had commitments extending to non-forest ecosystems such as savannas and grasslands — areas not currently protected under the EUDR. She called for greater attention to these ecosystems, as soy production is increasingly linked to the clearing of biodiverse non-forest areas, such as the Cerrado and the Pampas.
Reis echoed those concerns, saying the regulation’s forest-only focus leaves key ecosystems in South America at risk. He added that the EUDR and the Soy Moratorium should be seen as complementary measures, since the regulation alone would not prevent “indirect” deforestation in the Amazon if the moratorium ends, given their different cutoff dates (2020 and 2008, respectively).
“I believe the implementation of the EUDR will drive corporate commitments, but that doesn’t mean it will solve all the problems,” he said.
Thomson also expressed cautious optimism. “Even ahead of implementation, the EUDR has been a galvanising factor in pushing leading companies to invest in traceability,” she said, adding that once such infrastructure is in place, it could be easier for companies to implement deforestation-free supply chains beyond the EU. “Of course, the fact that it’s more workable to make and implement wider commitments does not mean companies will automatically do so, so it’s important that the spotlight stays on the companies that can make the most difference,” Thomson said.
Beyond corporate commitments, the spotlight should also remain on the regulation’s implementation, Reis said.
“As a matter of credibility and responsibility, the EUDR must be implemented this year,” the conservation specialist said, referring to the European Commission’s recent proposal to delay compliance beyond the original December 2025 date.
Banner image: Chaco forest destroyed for cultivating soy. Image by Rhett A. Butler/Mongabay.
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