Traceability for the EUDR: Lessons learned from the Brazilian cattle sector and recommendations to the EU

15 fevereiro 2024

Traceability for the EUDR: Lessons learned from the Brazilian cattle sector and recommendations to the EU

On 15 February 2024, Fern hosted a hybrid event at the Press Club in Brussels. Campaigners, decision makers and experts came together to discuss how to ensure public traceability systems can improve compliance with the EU Regulation on deforestation-free products (EUDR). 

The event focused on Brazilian supply chains, including whether the Brazilian cattle sector was ready to meet EUDR requirements in time for the application of the law at the end of December 2024.

Panellists recommended the following next steps to meet EUDR requirements:

  1. More and better European Commission information to dispel the myth that individual animal traceability is explicitly required for deforestation and legality, and guidance on legality criteria.
  2. National public traceability system should be universal and mandatory, like Brazilian public systems. Producer country governments should make publicly held data sets available to help verify legality claims. National systems should be recognised by the EU.
  3. Criteria for traceability systems should also apply to certification systems used under the EUDR. These criteria should be incorporated into the Commission’s guidance on certification systems, which Competent Authorities should be using in enforcement.
  4. Public traceability systems should provide positive incentives to producers that comply with sustainability criteria.
  5. Support producers and partner countries by addressing farmers’ fear of being stopped from exporting to Europe.
  6. The Commission should support countries to develop public traceability systems to meet these criteria, making expectations clear from the outset.
  7. Dedicate time to ensuring participation and understanding so as to improve acceptance of the EUDR requirements by famers in Europe and overseas.
  8. Governments and civil society should use this opportunity to further standardise, to unify industry approaches and to encourage consistency across the beef and leather sectors.
  9. When controlling deforestation, authorities should think more about ground-truthing. Relying on satellite data, which is not very high resolution, raises the risk of false positives. 
  10. Cross-sector representatives should come together to find and trial solutions and then scale them, both to meet the regulatory requirements and the broader ambitions of ending deforestation and land conversion

An extended summary of the discussion is below.


Fernando Sampaio of the Brazilian beef exporters association (ABIEC) gave an overview of the sector including that around 30% of the meat Brazil produces is exported. Europe imports around 3% of export volume, less than China, United States, and Chile, but in terms of value, Europe is very relevant. Only a few states in Brazil are currently licensed to export to Europe, but even for animals coming from those slaughterhouses, the whole lifecycle is not captured in documentation. Deforestation mostly happens outside the area where the fresh meat comes from, but every farm in Brazil must be recorded in the environmental registry. Data is cross-checked with satellite images provided by the Brazilian space agency.

The Brazilian meat sector wants to comply with the EUDR and has the technology to do so. The animal lives for between two and two and a half years before being slaughtered. So, this is the time they would need to fully comply with the EUDR. 

Tobias Fier of the German Meat Industry Association explained that Germany has 130,000 cattle farmers, and about 11 million head of cattle, and produces roughly one million metric tons of beef. In addition, in 2022, Germany imported about 46,000 tons of beef, in 2022, mainly from Argentina, Brazil and Uruguay. As well as imports, therefore, the EUDR is therefore of concern to German slaughterhouses, butchers, retailers and other companies who use nationally-sourced beef or nationally-sourced leather products, as they will have ensure they are compliant. Open questions include: how will the EU IT system works, and how will the industry association communicate information to the Competent Authorities. Nationally, companies must work with traceability systems to prove that there's no deforestation in Europe on its farms, and that is another big challenge to tackle. 

Earl Shank of the luxury fashion holding company Tapestry Inc. highlighted that although they do not place commodities or products on the EU market which fall under the EUDR’s scope, they work with EU-based tanneries who will need to comply. Tapestry supports them to identify sources of materials that comply with the EUDR and is preparing for the EUDR’s expansion to include finished goods. The company has achieved 95% mapping and traceability of raw materials to ensure a more responsible and transparent supply chain by 2025. He explained that a traceability system needs to be built with pragmatism in mind, which means designing and aligning around existing processes and systems. 

Marina Guyot of the Institute of Forest and Agricultural Management and Certification (Imaflora) highlighted the Beef on Track Programme for the Amazon, which is the result of more than ten years of collaboration between stakeholders. As the public prosecutor's office has participated in its creation, it is a reliable starting point from which to develop a national traceability system.

Beef on Track outlines how to monitor, verify, audit, and report on compliance with laws related to illegal deforestation, as well as overlaps with Indigenous Peoples’ lands, protected areas, environmental licensing, embargoes, and slave labour. It is stronger than many countries’ programmes, but does not yet deliver on some EUDR aspects, such as information on the indirect suppliers, the full life-cycle of cattle, zero deforestation (versus illegal deforestation). It also only covers the Amazon. Out of the 153 slaughterhouses in the Amazon biome only six have made a voluntary zero deforestation commitment.

Marina highlighted that dealing with these problems is important to avoid leakage, and that more data needs to be made public. Technical assistance and funds are needed to expand the Programme. 

Fern’s report exploring how the Brazilian Beef On Track monitoring system complies with the EUDR’s requirements can be found here: How to achieve zero deforestation in the cattle sector

Raoni Rajao of the Brazilian Ministry of Environment and Climate Change explained his department’s aim of reducing deforestation in all of Brazil’s biomes, and most importantly, illegal deforestation. 

The Brazilian Institute for Space Research found that products are still being bought from 87% of the areas embargoed by the federal law enforcement agency, Ibama. The Beef on Track Programme is an important tool to help reduce this as it blocks the acquisition of cattle from embargoed areas, as well as those with clear satellite evidence that deforestation is taking place there.

The Brazilian government plans to reduce deforestation in the Amazon and Cerrado biomes. The Ministry of Environment has proposed to develop a national traceability system and the Ministry of Agriculture is already developing its own system. Some Brazilian States have been quickly developing regional systems, so there is strong help to comply with both the EUDR, and national legislation. 

The Ministry also sees the importance of providing economic incentives to reduce all types of deforestation, as it cannot be solved by demand and control measures alone. He explained that there is no need to wait for individual cattle traceability while cross-checking herd data via animal transit documents. 

Simon Gmeiner of the European Commission said that the Commission’s International Partnerships focus on low-income countries, but that because Brazil is crucial, the Commission launched the Global Team Europe value chains initiative with Germany, France and the Netherlands, with an initial financial package of 70 million Euro. It builds on three pillars:

  1. The Sustainable Agriculture for Forest Ecosystems (SAFE) project, financed with 14 million Euro from the Commission and GIZ. It is currently being implemented in countries including Brazil, and will be expanding with an additional contribution from the Netherlands of 20 million Euro. There is a clear focus on including smallholders, and in Brazil, family farmers.
  2. An EU-supported technical facility on deforestation-free value chains. This flexible instrument will be operational in April and can be deployed by EU delegations when producer countries request it. It will focus on EUDR technical requirements such as traceability, but also look at legality.
  3. A zero-deforestation hub which will coordinate the above and existing projects and be operational in the middle of 2025. 

Julia Christian, Forests and Agriculture Campaigner at Fern, presented a soon to be released paper including recommendations for national public traceability systems the EUDR could leverage to help reduce deforestation and social problems. She explained the paper was based on interviews with traceability experts in Brazil, Cȏte d’Ivoire and Indonesia, who also confirmed that, where feasible, public traceability systems are preferable to multiple individual private systems.

The paper suggests five criteria to make a traceability system credible:

  1. It must be based on accurate and ground-truthed data.
  2. The data in the system must be publicly accessible.
  3. The system must have a multi-stakeholder oversight structure, which should meaningfully contribute to the design and the implementation/evaluation of the system.
  4. The system must undergo regular independent audits.
  5. A clear and accessible grievance mechanism, including being open to findings from independent NGO monitoring. The government must follow up on any grievances raised.

It also offers three criteria to drive change on the ground:

  • Give smallholder farmers control and access to data that they help to generate.
  • Respond to data needs of producer country actors (not just European companies) - e.g. small farmers want more information on payments made in the supply chain.
  • Link it to remedy and enforcement actions by the government.


Categorias: Events, EU Regulation on deforestation-free products, Brazil

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