Dr Chris West                            DEF0012

Written evidence submitted by Dr Chris West


I am Dr Chris West, a senior research fellow at the Stockholm Environment Institute at the University of York, where I manage a group focusing on sustainable consumption and production research. I support the UK and other European governments in the development of strategy on deforestation-linked supply chains; particularly from the perspective of the data and indicator landscape and monitoring and reporting of impacts. I am also a research leader within the data-driven transparency initiative Trase and the Trade Hub programme, which provide extensive relevant information which I reference here. My response also reflects consultations with leaders in both programmes.


The response below focuses only on commodity-linked deforestation, and not the UK timber industry.


As I have responded to many questions, my response exceeds 3000 words overall, but for ease of reading my response is laid out against each of the questions posed by the EAC with a summary message typically included at the top, and with sections which I hope will aid legibility. A repeated theme in my response is the need for increased investment in the monitoring and reporting of supply chains linked to deforestation, and continued dialogue with international parties to promote landscape-based transitions towards sustainable production.


I, along with my collaborators in Trase and Trade Hub, would be pleased to follow-up on any of the points raised below.


The effectiveness of UK efforts to reduce global deforestation


In what ways and to what extent are UK value chains (in the form of public procurement, goods, services, or the private sector) contributing to global deforestation?


There is an unequivocal link between UK value chains and global deforestation. The UK is a significant consumer of commodities linked to deforestation.


Key commodities


Table: Tropical and subtropical deforestation footprint of UK consumption, for top ten commodities, for the year 2017 (most recent available). Source: Formal UK ‘Global Environmental Impacts of Consumption’ indicator, compiled by SEI York in collaboration with the UK JNCC on behalf of Defra. For more information on this indicator: https://jncc.gov.uk/our-work/ukbi-a4-global-biodiversity-impact/ A dashboard has also been developed to represent this data: http://www.commodityfootprints.earth



2017 Tropical and subtropical deforestation footprint (hectares)

Cattle and buffalo meat


Oil palm


Industrial roundwood










Dry beans






Other commodities




The UK compared to other countries


While the UK has a significant and important footprint, it is a relatively small contributor to commodity-linked deforestation in global terms.


Figure: Total subtropical and tropical deforestation risk of multiple countries, across different trade perspectives (direct trade, indirect trade, and consumption-based). Top panel shows absolute footprint, bottom panel shows footprint per tonne of material (direct, re-export and consumption perspectives from left to right in Panel B). Source: Trase analysis commissioned by Germany's agency for international cooperation (GIZ): https://resources.trase.earth/documents/GIZ-report_Assessing-tropical-deforestation-in-Germanys-agricultural-commodity-supply-chains.pdf)


The UK has a significantly smaller footprint than that of China, but is among the highest of the ‘Amsterdam Declarations Partners’. From a ‘whole supply chain’ (consumption) perspective the intensity of UK consumption (footprint per tonne) is higher than that of China (UK deforestation intensity = 0.3 ha/1000 tonnes; China deforestation intensity = 0.2 ha/1000 tonnes; Source: Trase analysis for GIZ).


Limits of existing knowledge


Assigning remote land use change to discrete economic activities at points of consumption is complex. Different (but complementary) views of a deforestation footprint may be generated when looking at the UK’s direct imports from commodity-producing countries, when adjusting for re-exports, or when considering total consumption in the UK economy as a whole.


Quantifying the role of agriculture as a ‘driver’ of deforestation is also complex (a new Science synthesis paper “Disentangling the numbers behind agriculture-driven deforestation” due to be published on the 9th of September (I am a co-author) summarises best estimates). Complicating factors include the lags between conversion and the productive use of land, interactions between agriculture and other sectors, land speculation and indirect effects such as forest fires linked to human activities. But without the underlying consumption driver, many - if not most - of these more complex drivers that are indirectly linked to agriculture (like land speculation) would not exist or would be far less important.


Overall, attribution of impact to UK activities requires either a model-based approach (e.g. in the ‘Global Environmental Impacts of Consumption’ indicator; see below), or granular supply chain engagement and disclosure activities (e.g. that conducted by the UK Roundtable on Sustainable Soya, or the Retail Soy Group), or the thorough compilation and synthesis of publicly available information (like by Trase) to make concrete connections between public or private procurement activities. Currently, advances are needed across all of these strands of analysis (and the broader data landscape, including greater transparency in corporate and customs disclosures) to facilitate a better understanding of the UK’s contribution to deforestation.

How effectively is the Government monitoring the UK’s contribution to global deforestation and its progress in tackling the issue? And what progress has been made by Government to develop an indicator on overseas environmental impacts of UK consumption of key commodities?


Overall, the UK has contributed to the development of state-of-the-art monitoring systems, with spill-over benefits for other countries. There are, however, still significant challenges to overcome in order to ensure that these monitoring systems are truly effective forms of evidence to guide activities and to track changes in supply chains and landscapes of production. The production of such data and analysis will need adequate resourcing in the longer term, especially to move beyond high-level risk assessments to inform action in a more detailed way.


UK ‘Global Environmental Impacts of Consumption’ indicator


This provides a holistic account of the environmental pressure exerted overseas by the UK’s consumption. It was developed for Defra by SEI York in collaboration with JNCC in partnership with Trase and the GCRF Trade Hub. From October 2021, the UK has published the outputs (here). An update (to bring data up to 2018) is due in October 2022, with initial commitments from Defra to fund further updates in 2023 and 2024. Updates can now be developed relatively cost effectively.

It is encouraging to see acknowledgement of this indicator by the UK’s Global Resource Initiative, 25 Year Environmental Plan and Food Strategy, as well as support from the UK government to potentially establish it as a headline indicator under the CBD framework.


Development has involved differing levels of support from the UK government at various stages. Work began over ten years ago with the initial development of a methodology for monitoring the overseas impacts of consumption, which later became the peer-reviewed ‘Input Output Trade Analysis’ (IOTA) framework (described in Croft et al. 2018 and Green et al. 2019). Progress was supported by UK Research Councils, the UKRI Global Food Security programmes IKnowFood project, the Global Challenges Research Fund Trade Hub, under the Swedish Environmental Protection Agencies’ PRINCE and PRINCE 2 projects, and through Trase (currently funded by the Gordon and Betty Moore Foundation and NORAD, but with previous funding from the UK DFID). The lack of direct UK government support between 2012 and 2018/2019 was arguably a missed opportunity to accelerate development.


In the past two years, Trase (through SEI) has worked alongside the JNCC to develop IOTA outputs into the indicator (see methodological details here). Researchers from Chalmers University of Technology, Sweden, supply deforestation data inputs which the indicator relies on, generated from internationally recognised, peer-reviewed and state of the art methods.


Limits and challenges of the indicator


Holistic approach. As a model-based indicator aiming at a holistic account, the indicator is a mechanism to assess and triage the UK’s exposure to environmental ‘risk’ (see diagram below). It does not (and will not) align completely with industry-disclosed information. Please see GRI section below on how other information can support use of the indicator.


Figure: Suggested structure of a monitoring and reporting framework for the UK Global Resource Initiative, taking into account information requirements for both current and future commodity-linked risk assessments. The ‘Global Environmental Impacts of Consumption’ indicator sits at the top-most point of this pyramid, providing a holistic overview of the UK’s footprint, but with supplementary evidence needed to develop a comprehensive and robust monitoring system. Source: Global Resources Initiative Final Recommendations Report.


Commodity and biodiversity coverage. At the current time, the indicator covers agricultural, timber and cattle-based tropical and subtropical deforestation risks, in line with the underpinning Pendrill et al. 2022 dataset. Extension to other commodities is being scoped (mineral/mining work) or explored (e.g. for fisheries impacts). Work is also under way to improve the consideration of biodiversity impacts beyond the two simple metrics included to date.


Time lag. The time lag between the dataset (soon to go to 2018) and the current year is difficult to overcome using available data, but short-term projections could be explored.


Scale. The indicator has global coverage, but at national scale only. Platforms such as Trase highlight the importance of sub-national risk assessment, since land use change is often concentrated in confined geographic areas and subnational sourcing patterns across countries vary greatly. Incorporating sub-national information is due to be explored in conjunction with the JNCC, supported by Defra.


Wider challenges in the data landscape


Definitional and alignment problems. These are numerous. For example, the FAO Forest Resources Assessment definition of ‘forest’/’deforestation’ adopted by both UK and EU forest risk legislation is not aligned with the remote sensing products available to monitor deforestation. Details of other limitations of remote sensing products and global datasets can be provided on request.


Lack of supply chain transparency. Information disclosed in different jurisdictions and sectors is inconsistent and often inadequate. While Trase provides sub-national connections between production and consumption for some landscapes (e.g. Indonesia, Brazil), a lack of customs-information disclosure for other countries prevents this approach being rolled out at scale (e.g. for Malaysian oil palm). On the demand side, the UK and other European countries do not disclose the volumes of materials imported into the country by specified named importers, despite collecting the information necessary to do so. The lack of access to these data is a major limitation on supply chain transparency and our understanding of progress and barriers facing UK imports linked to deforestation.


If the UK government wishes to extend its monitoring beyond a high level risk assessment (for example to better understand the effects of interventions in landscapes of production), investments in addressing these challenges would be valuable. At the same time, in this complex context, ‘perfect’ information will never arrive - and it is also possible to improve utilisation of the information already available.


Additional analysis for the UK


Trase has prepared reports for the German and Belgian governments, based on the application of the IOTA modelling framework and Trase’s sub-national data, which go significantly beyond the high-level analysis provided formally as part of the UK ‘Global Environmental Impacts of Consumption’ indicator (see here for the report for the German government[1]). I (and Trase) would welcome further contact from the UK government about the potential to expand analysis for the UK, including to support an annual assessment of risk exposure and opportunities for targeted action.


How effective are the measures to improve due diligence and ban imported products of illegal deforestation in the Environment Act 2021? Do these measures target the right sectors? Given that they do not extend to all products of deforestation, are they adequate?


SEI and Trase welcome the regulatory intervention of the UK. A legislative response is necessary as voluntary private sector commitments on deforestation have failed to meet their ambitions. (See previous SEI consultation responses here and here)


However, we have highlighted potential weaknesses of the UK’s approach which remain of concern. (See three Trase policy briefings on UK, EU and US legislation).


Legality, not zero deforestation


Firstly, in contrast to the EU, the UK has adopted a legality-based rather than zero-deforestation approach. This is intended to respect the sovereignty of producer countries and promote ongoing dialogue to ‘raise the legislative floor’ in production areas. However, legal deforestation is also important and would not be removed from UK supply chains. This limitation has been pointed out by the private sector (link), and recent voluntary commitments (such as the UK Soy Manifesto) go beyond regulatory approaches. Evidence suggests that many important countries are not raising their environmental standards, and may legally meet UK market demands while continuing to deforest (Reis et al. 2021).


The requirement for compliance with ‘local laws’ is not limited to laws on deforestation. Protections could in theory extend beyond forests (e.g. the biodiverse Cerrado savannah in Brazil, a major commodity sourcing area (see this report by Trase)) or encompass forest degradation, which can cause greater biodiversity loss than deforestation itself (Barlow et al. 2016). However, these effects depend on the legal frameworks in producer countries.


Businesses in scope


The UK’s regulation applies to all large businesses handling materials linked to the commodities in scope. In theory, this means deforestation could rise up the agenda of the complete UK supply chain, which is particularly important to foster voluntary measures which extend beyond legality. This regime places shared responsibility for the data collection required to demonstrate due diligence on all businesses in the supply chain. Information sharing across the supply chain can expedite action and promote the sharing of best practices, but it may also lead to duplication of effort, bringing inefficiencies and costs. It is important that the government plays a core - and appropriately resourced - role in the design of data collection requirements, to ensure adequate support, information sharing and disclosure for monitoring purposes.


The legislation will not apply to small businesses directly, so that illegal material could potentially enter the UK market via smaller actors. These total quantities may be significant, although it is hard to assess this as UK customs information in the public domain does not allow the linkage of import volumes to individual entities. Smaller companies appear to have been excluded (in contrast to the EU legislation) to avoid the burden of costs. However, many are part of the supply chains of larger companies subject to the regulation and therefore likely to have requests for data imposed upon them via their clients. The government should therefore think carefully about providing support to small companies and indeed extending the legislation to them with such support. Support requirements for data providers outside of the UK, e.g. producers in other countries, should also be carefully assessed, given that they may also be asked to provide data with little or no financial compensation from the UK supply chain.


Staged introduction of commodities


The government has proposed staging the introduction of commodities in scope, from as little as two initially, with up to 7 in four or five years. Excluding forestry products (which are outside of the scope of Schedule 17; another contrast to the EU approach), the UK ‘Global Environmental Impacts of Consumption’ indicator suggests cattle meat products, palm oil and soy have the highest tropical and subtropical deforestation footprint. Excluding maize (often grown alongside soy in deforestation frontiers), or cocoa and coffee (associated with regionally important deforestation activities) risks missing a one-time opportunity to set early and clear expectations that deforestation is not welcome in any UK supply chains. The justification for staging is also unclear. Given the importance of the regulatory aims, the government is encouraged to commit to adequate resourcing to avoid a staged approach.


Penalties for non-compliance


In its recent consultation, the government suggested that the maximum penalty for non-compliance would be £250k, in line with the Ivory Act.


A higher penalty should be considered to incentivise compliance. Ivory is a relatively ‘niche’ product with good public awareness of its environmental harm, which may support enforcement processes. By contrast, deforestation-linked commodities may be found in a variety of products as part of global agribusiness supply chains, and legal and illegal material cannot be readily distinguished based on their appearance. Many businesses handling deforestation-risk materials have high financial turnovers (up to several billion pounds per year). This, coupled with potential enforcement challenges (in part linked to data availability limitations), support raising the penalty.


Alignment with EU legislation


As summarised in the Trase briefs linked above, there are several differences between the UK and EU legislation. This has the potential to increase the volume and quantity of information required of businesses operating within both contexts. It may also lead to segmented supply chains, designed to meet respective EU and UK requirements, which - whilst adding costs - do not address the deforestation overall in important areas of production. Despite legislative differences, there remains an opportunity for the UK to work closely with Europe on the continued development of deforestation-free policy and activity, including in addressing the data-related and monitoring challenges highlighted elsewhere in this document. 


To what extent have the Global Resource Initiative (GRI) Taskforce’s recommendations on deforestation and land conversion been met by the Government?


I acted as an Advisor for the UK Global Resource Initiative, particular in relation to the Monitoring and Reporting recommendation. I will comment only on a few aspects of the recommendations:

Environment Act Schedule 17

The UK government should be commended for rapidly introducing Schedule 17 in response to GRI recommendation 2a. However, the GRI’s recommendations went beyond legality, and envisioned similar regulation for the finance industry, who currently fall outside the scope of the legislation. Additional investigation coordinated by Efeca as a subcomponent of the GRI again recommended a legal duty on the finance sector, in alignment with the Schedule 17 at first and eventually extending beyond legality.


Mobilising global call for action


Another concrete success story concerns recommendation 3c of the GRI (“The government mobilises a global call for action to tackle deforestation and build sustainable commodity supply chains in the lead up to COP26”). At COP26, significant progress was made, with global signatories to the COP26 Forest Declaration going beyond signatories to the New York Declaration on Forests (which had not included, for example, China or India), and the establishment of associated funding commitments (see below).


Establishment of a formal target


Recommendation 1b of the GRI called for a legally binding target to end deforestation within UK agricultural and forestry commission supply chains by 2030. The government responded by committing to the development of an indicator (now the ‘Global Environmental Impacts of Consumption’ indicator) but to my knowledge a formal target has not yet been established. A key challenge here remains the broader data landscape necessary to monitor progress (see below on Recommendation 4b).


Partnerships, dialogues and trade


Recommendation 3a suggested a bold new approach to partnerships, dialogues and trade between producer and consumer countries, working together to develop solutions that support the transition to sustainable commodity supply chains that are fair and equitable. This is central to any broader UK strategy as deforestation is linked to many other consuming countries. Furthermore, given the limitations of the legality-based regulation, partnerships, dialogue and trade agreements will play an integral role in any upgrading of local legislation and in the broadening of demand-side legislation beyond first movers such as the UK and EU.


Some undoubted progress here includes continued leadership within the Amsterdam Declarations Partnership, promotion of the ‘Global Environmental Impacts of Consumption’ indicator within CBD processes, the establishment of the FACT Dialogue in the run-up to and post-COP26, and interventions with international traders.


Yet there is still work to be done. The dynamics of the commodity production/deforestation interface are distinct in different regions, requiring an understanding of those contexts if interventions are to be made positively and with due regard for human rights and development. There is broad recognition that to effectively deliver reductions in deforestation, regulations such as due diligence measures need to be coupled with strong incentive based measures. Yet current partnership agreements are fragmented and partial, lacking alignment on the type of engagement activities and investments that are most urgently needed to strengthen “forest partnerships” between producer and consumer countries. The UK government has an opportunity to work with partners in Europe and elsewhere, as well as major producers of forest-risk commodities such as Brazil and Indonesia, and help ensure that the “whole is greater than the sum of the parts” when it comes to the combined effect of these agreements.


And there is a particular need to foster cross-departmental communication and an understanding of commodity deforestation across all relevant government departments. As an important example, while it is my understanding that Defra provided evidence to inform the development of the UK government’s strategy for FTAs (the responsibility of DIT) with India, Australia and the CPTPP, the resulting strategic documents contain almost identical statements, rather than reflecting different approaches based on the relationships of those trading partners to commodity deforestation.[2] 


The government has stated that “Free Trade Agreement (FTA) negotiating teams are exploring options in the design of future trade and investment agreements, with the aim of securing high ambition sustainability provisions with key trading partners, drawing upon existing FTA precedents to enhance cooperation on areas such as biodiversity, forestry and supply chains.”  Potential data providers (e.g. JNCC or relevant experts such as SEI/Trase) should be informed of the current data required by the Government to ensure FTA-linked opportunities are realised.


Monitoring, measurement and reporting


Recommendation 4b calls for the government to support the development of a monitoring, measurement and reporting framework to support the implementation of GRI  recommendations. These are to cover current and future commodity supply chain forest risk, impact and response, building on the core principles of the Accountability Framework Initiative (AFi). This recognises the necessity of aligning monitoring and reporting activities with international best practices.


The government has agreed to explore the scope of the ‘Global Environmental Impacts of Consumption’ indicator “as a tool to support the monitoring of our policy interventions and our progress in reducing the UK’s overseas deforestation risk”. Supported by Defra, SEI/Trase and the JNCC have started scoping out opportunities to provide a more comprehensive monitoring framework. This must incorporate data from across scales, including from the private sector, where greater transparency and information disclosure is an imperative. Efforts via diplomatic channels to promote international data disclosure (and domestic disclosure of UK customs and industrial data) will also pay significant dividends in improving UK, and global, monitoring of risk.


This work between Defra, the JNCC and SEI/Trase will be consultative, involving expertise from the private sector and policy spaces, along with leading international academics. The work over the next 12 months or so will undertake scoping only; the eventual implementation of a fully robust monitoring system will require additional resourcing, especially if it is to incorporate the data state of the art, fill data gaps, align with other monitoring systems internationally (including the EU’s proposed Observatory on deforestation and forest degradation), and prove useful across UK government departments and by UK industry. While focused on the UK’s deforestation risk, such a system may have spillover benefits in other domains. For example, the UK Government’s Climate Change Risk Assessment 2022 highlights climate impacts that are likely to ‘cascade’ into the UK - including via trade. Our research linked to an EU programme (www.cascades.eu) has also highlighted a requirement for greater supply chain transparency and enhanced monitoring of supply chain activities to build future resilience to such risks.


What role can sustainable certification and Government Buying Standards (GBS), have in tackling deforestation? How can the UK Government support the private sector to reduce its contribution to furthering deforestation?


I have no expertise on Government Buying Standards.


It may be possible for the UK government to use certification as evidence of deforestation-free supply, but only if a) recognised schemes have been scrutinised for their effectiveness in avoiding deforestation; b) they provide guarantees that the material sourced into the UK has been sourced from regions which are deforestation-free; and c) company disclosure activities on the use of recognised schemes is promoted to allow assessment the extent to which certified supply into the UK is supporting a deforestation-free economy. Some of the limitations of certification to date are described in more detail below.


Limitations of scale of impact


Certification schemes to date lack a strong track record in reducing landscape-scale deforestation rates. By definition, they lend themselves to a bifurcated market and a concentration of more sustainable production in landscapes that were deforested longer ago (reducing their ability to drive down overall deforestation rates). For example, despite high international awareness of the link between palm oil and deforestation (which explains the fact that certified uptake is higher for palm oil than for other commodities), RSPO palm oil makes up only around 19% of total global production (i.e. international ‘willingness to pay’ for certification is insufficient) and deforestation continues in palm oil production landscapes. For soy, uptake of standards such as RTRS (established in 2006) remain relatively low, covering only 4.6 million tonnes of soy production globally.




Labelling can promote the uptake of certified standards via consumer demand. Yet anecdotal evidence suggests that some companies avoid labelling products as having ‘sustainable’ sources (e.g. via RSPO labels) for fear of drawing consumer attention to the presence of palm oil in products. Furthermore, for many products, materials ‘embedded’ in production are not included on product labels. For example, the sources of animal feed do not have to be included in packaging for meat products as they are not ‘ingredients’, so the bulk of soy material used in the UK in animal feed is not reflected on labels.


Types of certification


Historically, much material has been certified under ‘credit-based’ systems designed to ensure that a certain mass of material somewhere has been produced without deforestation. This does not guarantee that the specific material used in any particular supply chain is deforestation-free. Regional credit systems (which guarantee sourcing from a particular region or landscape without specifying the exact origin), mass-balance, or segregated certification schemes offer alternative options (some of which can guarantee physical supply of deforestation-free material), but come with additional costs (price premiums). Such premiums are often relatively small, but again willingness to pay has historically been low.


An additional complexity is a lack of standardisation across schemes. Initiatives such as the ISEAL Alliance promote standardisation, but assessing the extent of alignment between schemes (and therefore their relative robustness) still requires screening of individual schemes. Recently, major manufacturers have created their own schemes, confusing the landscape further.


Difficulty of monitoring


The use of certification to demonstrate deforestation-free supply is currently challenging (see this JNCC report exploring this in relation to UK impact). Information on certification is typically not captured by international trade statistics, meaning that monitoring sector or country-wide uptake of certification requires bespoke activities. Examples include the work of the UK Soy Roundtable who have worked with AIC in the UK to assess certification coverage of UK soy.


Recommendations for supporting the private sector


        The government will need to assist small businesses in their obligations to larger clients subject to incoming regulation.

        The UK government can contribute to the broader landscape of monitoring (including supporting data improvement and alignment) that interfaces with industry data and its own risk assessment processes.

        The UK government can continue to actively support dialogue with companies, including via the UK commodity roundtables, and supporting ongoing processes based on the multi-stakeholder model used for the GRI Taskforce.

        The government can pay heed to the existing GRI recommendation to introduce mandatory due diligence for the financial sector.


Working with international partners to tackle deforestation


How effectively is the UK engaging with international partners to tackle deforestation? Is the Glasgow Leaders Declaration on Forests and Land Use an effective mechanism for halting and reversing forest loss? How can the UK ensure its £1.5bn commitment to the Global Forest Finance Pledge is used to best effect?


See some commentary on international engagement (including the EU) above. I also recommend synthesising materials from those directly involved in the FACT Dialogue. Many of the ideas that emerged from FACT remain pertinent. For example, in the transparency and traceability working group, an early idea was to develop a facility to help harmonise disclosure of data by producer and consumer governments.


The Glasgow Leaders Declaration was a landmark pledge. But the most important work is now to come - demonstrating, through ongoing UK leadership, how countries can be encouraged and supported to fulfil their commitments as signatories to that pledge.


Engaging other consumer countries


It is imperative that engagement occurs with other major consumers of deforestation risk material. Dialogue with China is particularly important, including because of the important role China plays in the UK’s supply chain, where China’s imports may eventually be destined for the UK market. China’s role in the upcoming CBD COP provides an important opportunity to engage.


Encouragingly, in its response to the GRI recommendations, the UK recognises the important potential role of the WTO, as both an enabler but also as a barrier for change (given concerns around the principle of non-discrimination). Other platforms such as the G7 (which the UK government has already used), the G20 (with Indonesia hosting providing a key opportunity) and the OECD will be important too.


The UK’s £1.5bn commitment to the Global Forest Finance Pledge would ideally be targeted at critical deforestation frontiers, regardless of their explicit connections to UK supply chains. Scaling up landscape based approaches is key. Commodity-based approaches are insufficient, given the complexities described above and the potential for leakage effects. The UK can use this funding to understand how leading examples of landscape or jurisdictional based approaches (such as the PCI Initiative in Mato Grosso, Brazil, and LTKL in Indonesia) can be scaled up and translated into new jurisdictions or biomes. Additionally, investments must be supported with effective monitoring, evaluation and learning.


What is most critical is that a minimum level of alignment is sought, not just with the national producer governments in question but also other donor countries - for example by aligning together on the highest priority investments for partnership agreements, e.g. to provide the enabling conditions necessary for producer countries to ensure individual farmers can be compliant with due diligence legislation.


What impact will the UK’s measures to tackle deforestation have on producer countries, indigenous peoples and local communities?


This is not an area of personal expertise, but I would encourage the UK Government to engage with WCMC who lead the Global Challenges Research Fund Trade Hub project which is working with many international partners with knowledge of the implications of supply chain activities on local communities and producer countries.


September 2022

[1] This is believed to represent the most comprehensive and in-depth cross-commodity assessment yet possible of the deforestation footprint of a European country.

[2] From Australia: “The overall impacts on resource use and biodiversity globally are difficult to fully assess, as some additional production could be the result of trade diversion from less efficient producers based in countries with lower environmental standards. For example, in some large agricultural exporters, deforestation for agricultural land use takes place, with negative consequences both for biodiversity and climate change. Until the final negotiated outcome is known, it is difficult to accurately quantify trade diversionary effects.”

From CPTPP: “The overall impacts on resource use and biodiversity globally are difficult to assess fully, as some additional production could be the result of trade diversion from less efficient producers based in countries with lower environmental standards. For example, in some large agricultural exporters, deforestation for agricultural land use takes place, with negative consequences both for diversity and climate change.”