Commodity-driven Deforestation in Indonesia (FGD “Respon dan Posisi Indonesia terhadap Draft Delegated Regulation Uni Europa”)

EU 2019 Report … on the status of production expansion of relevant food and feed crops worldwide (draft)
  • Indicates that 10-30% tree cover is debatable, but the continues to work with >10% threshold
  • Ignores potential for forest to grow as well as actual land use, as satellite imagery cannot accurately identify either
  • Assumes deforestation is solely driven by the main commodity, a serious oversimplification
GFW: “Loss” indicates the removal or mortality of tree cover and can be due to a variety of factors, including mechanical harvesting, fire, disease, or storm damage. As such, “loss” does not equate to deforestation. ( For more information, see
Ergo, no link between EU’s ‘expansion’ and the identified tree cover loss.
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