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The EU and its Attempt to Curb Deforestation – Some Critical Reflections on the Commission’s New Proposal

Georg Miribug

On 17 November 2021 the European Commission published a proposal that would ban placing on the market certain raw materials and products linked to deforestation and forest degradation as well as making them available within the single market or exporting them from the EU. With this proposal the Commission intends to introduce strict due diligence obligations for operators and traders who place these raw materials and products on the market in the EU or export them from the EU. This paper analyses the proposed regulation, focusing on two issues: first, the subject matter of the regulation, and second, the due diligence procedure. It is argued that specific instruments of cooperation between the EU and producer countries could be very helpful in implementing due diligence. They may help to reduce conflicts of interest between producers and the EU by combining unilateral requirements (from the EU) with bilateral instruments (cooperation). Despite this positive approach, the proposed regulation contains some weak points that have been identified in this paper, such as unclear and narrow definitions and existing loopholes that could be exploited to circumvent the requirements.

Freie Universität Bozen, Fakultät für Naturwissenschaften und Technik. For Correspondence: <>


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