The French National Strategy to Fight Imported Deforestation (stratégie nationale de lutte contre la déforestation importée: SNDI) seeks to combat imported deforestation by 2030, which it defines as ‘the importation of raw or processed materials whose production contributed, directly or indirectly, to deforestation, forest degradation or to the conversion of natural ecosystems outside of the national territory’. The commodities defined as drivers of deforestation include palm oil, soy, rubber, beef, maize, cocoa and coffee, but also timber.
Corporate transparency and responsible finance
The SNDI’s objective 12 highlights the potential role that responsible finance can play: the explicit integration of deforestation issues in financial sector strategies and policies is a key tool to tackle imported deforestation (for more detail, read our commentary on the draft version of the SNDI). To support financial sector due diligence and decision making, the SNDI also emphasises the importance of corporate transparency and extra-financial reporting:
- The strategy includes a proposal to review Directive 2014/95/EU which forces large companies to include non-financial statements in their annual reporting. This push for increased and more meaningful disclosures is also echoed by the Alliance for Corporate Transparency whose aim is to promote the “development of the EU sustainability reporting framework”.
- Further to France’s recent adoption of legislation requiring certain companies to implement due diligence with regards to environmental, social and governance (ESG) risks in 2017, the final version also confirms the French government’s intention to push for this due diligence obligation to be implemented at EU level.
Improving certification and increasing sustainable supply
The order in which the strategy’s two proposed certification measures appear was swapped in the final document: the paragraph on improving certification now comes first, with the paragraph relating to increasing the share of sustainable materials in second place.
This small but perhaps not insignificant change to the draft strategy might reflect NGO calls to strengthen certification schemes, which may lack stringency or have insufficient implementation.
- Improving certification schemes (measure 13-1): the strategy raises a comprehensive range of ESG issues commonly found in soft commodity supply chains and assessed on SPOTT:
- the adoption of High Conservation Values (HCV) and High Carbon Stock (HCS) methodologies
- no planting on peat and criteria to avoid conversion of forest to other land uses
- adoption of Free, Prior, and Informed Consent (FPIC) processes and commitments
- references to labour rights and International Labour Organisation (ILO) conventions
- smallholder support
- Increasing certification uptake (measure 13-2): The SNDI proposes to support the uptake of procurement policies (objective 12), improve product labelling (objective 10) and promote responsible consumption through awareness campaigns (measure 14-2).
Illegal timber and deforestation
The final strategy goes slightly further than the draft version in addressing the link between illegal timber and deforestation. The draft strategy relied on the existence of other policy instruments (such as FLEGT and the EU Timber Regulation or EUTR) to tackle imported deforestation linked to the timber trade. This seemed insufficient considering that in 2015, a Chatham House report estimated that ‘As much as half of all tropical timber traded internationally now comes from forest conversion, of which nearly two-thirds is thought to be illegal’.
The final document also sets out measures related to the implementation of the EUTR (measure 9-1). These measures include:
- an increase in police powers to enable specialised agents to carry out controls
- a proposed annual target for checks on importers first placing timber and timber products on the European market set at 175 – which amounts to an increase of less than 10% when compared with the number of reported checks on operators dealing with imported timber for the period 2015-2017 (320 checks in two years).
The role of Biofuels
Another aspect of the strategy is to reduce the proportion of imported deforestation associated with biofuels, but the draft version mainly referred to upcoming decisions and reports to be adopted at EU level. Among others, the final version of the strategy outlines the following measures:
- Setting a cap on first generation biofuels based on 2020 use and below 7% as agreed in the EU Renewable Energy Directive. According to the strategy, biofuels based on palm fatty acid distillate will be among the biofuels targeted by this decision (measure 6-4).
- Starting the phase out of biofuels made with raw materials presenting a high risk of indirect land use change (to be defined by the European Commission), with a cap at 2019 levels until 2023 and phased out through to 2030.
- Supporting the European commission in reinforcing the sustainability criteria for products potentially driving deforestation and their effective application by 2023. Together with another proposed measure related to implementing the segregation of raw material batches (measure 6-5), this may force commodity supply chains to act quickly to respond to increased requirements.
As more stakeholders are urged to take notice of imported deforestation and the displaced impacts of commodity production patterns in France, in the EU and internationally, find out more about how SPOTT tracks transparency and supports sustainability in the palm oil, timber and pulp, and natural rubber sectors: