Conditions for an effective EU regulation on deforestation-free products: Where will it likely reduce deforestation?
Abstract. In 2023, the European Union (EU) adopted the Regulation on Deforestation-free Products (EUDR) to curb deforestation and forest degradation linked to its agricultural and wood trade. While existing research has outlined how the regulation is expected to work when implemented from 2027, we still have a weak understanding of how these mechanisms are likely to play out across different country and commodity contexts. This study focuses on the conditions under which different outcomes emerge, encompassing both intended impacts and potential spillover effects. We highlight that the regulation is likely to produce heterogeneous, context-dependent outcomes in reducing future deforestation across commodities and countries, with EU market shares and associated deforestation embodied in EU trade being key conditions. Evaluated in absolute terms, the EUDR may not substantially reduce global deforestation or emissions, but it could be effective in certain contexts. Our results suggest that high EU market shares (e.g., cocoa, coffee) offer leverage, while low market shares (e.g., soy, palm oil) increase risks of market segregation and negative spillovers. The EUDR’s most significant source of leverage likely stems from its broader influence on forest and supply-chain governance among multinational companies and non-EU countries. Achieving this wider impact requires coordinated collaboration with both producer and other consumer countries.
This is a truly interesting piece of work that, if published soon, would be timely given the expected rollout of the EUDR by the end of 2026. I believe it can contribute to the literature on transnational regulation, policy analysis, and multi-stakeholder governance for agri-food commodities. I recommend minor adjustments before publication.
The article is particularly strong in stressing the importance of acknowledging that the EUDR will likely have heterogeneous effects when implemented. While expecting heterogeneous effects might seem obvious (given the diversity of commodities and producing countries and regions, it would be highly unlikely otherwise), the paper offers an analysis of a set of ‘conditions’ (mainly market aspects) that exemplify precisely why and where heterogeneity is expected. The analysis relies on quantitative data evidence, and the main theoretical underpinnings stem from economics and public policy analysis. The paper advances the understanding of the potential EUDR effectiveness, policy design shortcomings and policy implementation challenges. I have uploaded a PDF with my suggestions for minor revisions/improvements. I list my comments according to the subtitles within the manuscript.