Ivorian NGO identifies issues related to implementing the EU Deforestation Regulation in the cocoa sector

15 marzo 2023

Ivorian NGO identifies issues related to implementing the EU Deforestation Regulation in the cocoa sector

Cocoa is being grown illegally in protected areas in Côte d’Ivoire, found a report published in February 2023 by the Ivorian NGO Initiatives pour le Développement communautaire et la conservation de la Forêt (IDEF). The study offers insights about practical challenges that decision-makers should consider in the interim period before the EU Regulation on deforestation-free products (EUDR) comes into force, and that private companies will need to address.

IDEF’s independent monitoring missions to Mount Peko national park found that cocoa grown illegally within the park has a high risk of entering the supply chains of large trader Cargill, an important supplier to the EU market. Cargill’s deforestation-free traceability system is undermined by the fact that the farmers’ cooperatives supplying Cargill are mixing deforestation-free cocoa with cocoa grown in the protected area.

Companies will need to fix such problems if they are to comply with the EUDR, which requires companies to ensure that the cocoa they are placing on the EU market is deforestation free.

IDEF’s report also identifies an important problem regarding the reliance of the EUDR on satellite data. The report explains that, according to Global Forest Watch (GFW) satellite data, the Mount Peko national park appears to have experienced heavy deforestation since 2020. However, IDEF’s ground missions reveal that the latest post-2020 “forest cover changes” that appear in the GFW satellite data are not deforestation, but are actually clearances of illegal cocoa plantations by the government parks agency.

These cocoa plantation clearances are both legally mandated and positive for sustainability purposes, as they permit the reconstitution of the park’s lost forest cover – also, they do not legally constitute “deforestation” according to the definition used by the EUDR. Yet relying on satellite data alone would give the EUDR implementors the impression that deforestation is happening.

IDEF recommends that, in order to avoid the type of confusion described above, the EU should ensure that its use of satellite images – for example in its deforestation-risk benchmarking of different countries, or its checks on companies – is coupled with “ground-truthing” field surveys by independent actors like NGOs.  As the EU develops its benchmarking procedures and implementing acts to the Regulation, it should consider how to enshrine this role. 


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