© Marcio Sanches / WWF-Brasil
No ecosystem left behind

Join us in urging the Members of the European Council, Commission, and Parliament to embrace the imperative of the inclusion of natural   Other Wooded Land (OWL) aligned with the Forest Resource Assessment categories from FAO, within the scope of the deforestation definition in the Regulation on Deforestation-free products, known as European Union Deforestation Regulation (EUDR).

Our call echoes the proposed Amendment 88 by the European Parliament, with a holistic approach that defines deforestation as the conversion, whether human-induced or not, of forests or OWL to agricultural use or to forest plantation;

Considering that, in Brazil, the biggest share of environmental degradation and human rights violations embedded in commodities imported by Europe is associated to deforestation and conversion of Cerrado, and that OWL is still not included in its scope, the EUDR covers only 26% of Cerrado, the regulation will be unable to fulfill its objective of reducing the footprint of EU consumption on carbon emissions (Green Deal) related to the destruction of natural ecosystems  and encourage EU consumption of products from deforestation and conversion-free (DCF) supply chains. And even at the risk of forest-only-focused approaches to create an even more considerable rebound pressure of destruction on non-forest ecosystems, their local communities, and indigenous peoples.


According to all recent IPCC and IPBES Reports, the climate and biodiversity crises are interconnected: limiting global warming and protecting nature are mutually supportive, interdependent goals. Ending deforestation and conversion is critical to both. Land-use change is the main driver of ecosystem and biodiversity loss worldwide, with 75% of the world’s land surface already significantly altered. Agriculture, Forestry and other Land Use (AFOLU) account for 23% of greenhouse gas emissions, causing climate impacts that further threaten biodiversity, with potentially catastrophic feedback loops.  

Three commodities represent the main drivers of deforestation and conversion, and related emissions and other major impacts within the food sector – beef, palm oil and soy. Natural habitat conversion of these 3 commodities together are responsible for between 40-50% of agricultural land-conversion emissions and between 9 and 12% of total food systems emissions. As the global market demand for commodities, specially soybean and meat, increases more and more, many forest, savannah, shrubland and woodland vegetation areas are being converted to agricultural land, contributing to the unbridled destruction of forests and savannahs. The productive chains of these commodities, along with the process of real estate speculation, are the major drivers of deforestation and conversion in key biomes such as the Cerrado and Amazon. 

And this can, among other things, collapse unique ecosystems, extinguish species, and alter the flow and existence of the so-called "flying rivers" that regulate the rains that supply Brazilian agricultural production - for example. Studies point that between 1985 and 2012, deforestation and the consequent increase of temperatures have caused a reduction of 6% of the soy production productivity in Cerrado, with the MATOPIBA region reaching 20%. 

It's time to turn this game around! In the Cerrado, it is possible to considerably increase productivity using already degraded and underutilized areas without cutting down any more trees, shrubs and grasses, greatly reducing the pressure for commodity production and guaranteeing food supplies without further damaging our biomes.

Data from the Pasture Working Group studies show that there are 27.4 million hectares of degraded pastures in the Cerrado with economic potential for intensified grazing, dairy farming, soybeans, ILPF (crop-livestock-forest integration), and agroforestry systems (learn more here).

According to FAO: Other Wooded Land is land with a canopy cover of 5-10 percent of trees able to reach a height of 5m in situ; or a canopy cover of more than 10 percent when smaller trees, shrubs and bushes are included.

© Marcio Sanches / WWF-Brasil


The European Regulation on deforestation-free products is an opportunity to:
1) respect and consider national efforts for traceability, ensuring efficiency in the implementation of guidelines;
2) ensure that fundamental ecosystems do not collapse;
3) guarantee the human rights of indigenous peoples and traditional communities.

Cerrado natural OWL are the main place where soy is produced and expands

Savannas and natural grasslands, such as the Brazilian Cerrado, play a vital role in ecosystem services and are the livelihood of indigenous people and local communities. The expansion of soy on Cerrado savannas, if unprotected by legislation, would intensify the destruction and human rights violation in the biome associated with Europe imports. Protecting forests alone is not sufficient  and could result in an increase of pressure to savannas, which is counterproductive to the desired environmental preservation.  

The European Union is the third largest buyer of soy from Brazil, where 43% of total volume are coming from the Cerrado. Also, more than 20% of the soy produced in the Cerrado are exported to the European Union (trase, 2018, 2022).

The consequences of non-inclusion of natural and primary OWL in the regulation scope:

As Amazon Soy Moratorium (ASM) already aims at protecting the Amazon forests, a leakage of conversion from Cerrado forests to unprotected OWL would occur due to exacerbate soy expansion, as already experienced in Cerrado after ASM implementation. 

Pressure and Human Rights violations will increase on Cerrado Indigenous People and Traditional Communities 

The EUDR already requires traceability to the plot of land for the products that enter the European market, including commodities produced in non forest ecosystems. Accepting that these products can be associated with human rights violations or conversion of natural ecosystems under the pretext that they do not come from forests is not justified and would have a high moral cost.

The FAO, Food and Agriculture Organization of the United Nations, defines "Other Wooded Land" (OWL) as wooded lands with a tree canopy cover of at least 5%, a minimum height of 5 meters, and an area of at least 0.5 hectares, excluding lands predominantly under agricultural or urban uses. This FAO definition inclusion in the EUDR is crucial for understanding and distinguishing wooded lands from forests, especially in the context of environmental legislation and conservation practices. 

Technical considerations to the definition and the EUDR: 

  • Difficulty distinguishing forest and OWL in mosaic and gradient landscapes, which generates uncertainty in the mapping of the law's scope.
  • Facilitate the implementation of the EUDR with extended scope by no longer needing to distinguish (and not having the problem of associated uncertainty).
  • Extending the scope of the EUDR to natural and primary OWL will increase the coverage of Cerrado conversion from less than 20% to more than 80% (60 Mha). This would avoid the Regulation to have unintended impacts of increasing damage to already threatened non-forest ecosystems in Brazil.


A Historical Opportunity to Protect the Environment and Human Rights
Regulation on deforestation-free products is a historic opportunity to ensure the human rights of indigenous peoples and traditional communities. In addition to environmental concerns, the EUDR expands its scope to social aspects, requiring these products to comply with international human rights provisions and respect the rights of indigenous peoples and traditional communities. In the case of Brazil, the Amazon is the only biome with a larger protected forest area (91%) under the regulation, followed by the Atlantic Forest (87%). Of the other biomes, only small percentages of the Cerrado (26%), Caatinga (11%), Pantanal (24%), and Pampas (26%) are covered by the regulation.

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This move is considered a victory by environmental advocates, especially if additional forested areas like the Brazilian Cerrado are included in the European regulatory framework. The Cerrado, responsible for 5% of the planet's biodiversity, has already lost half of its native vegetation.

The broader application of the proposal to include various biomes is in line with the perspectives of experts who emphasize the interconnectedness of regions and the need to consider both ecosystems and the rights of indigenous communities in global efforts for climate balance. Indigenous peoples in Brazil, present in all biomes, already face pressures from commodity production, including illegal invasions, deforestation, violence, and threats.

Given the increasing risk of environmental degradation, there is a clear need for more comprehensive anti-deforestation regulation to ensure global biodiversity protection and the survival of traditional communities, contributing to global climate balance.