G/AG/GEN/213  
 
29 November 2022  
(22-8872) Page: 1/5 
Committee on Agriculture  Original: English  
 
 
 
JOINT LETTER  
 
EUROPEAN UNION PROPOSAL FOR A REGULATION ON DEFORESTATION -FREE PRODUCTS  
Submission by Indonesia  and Brazil  
The following submission, dated 28 November  2022, is being circulated at the request of the 
delegation s of Indonesia  and Brazil . 
 
_______________  
 
 
This joint letter is being circulated to the Committee on Agriculture for transparency purposes only.  
  G/AG/GEN/213  
 
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  Brussels, 27 July 2022  
 
 
Honorable Roberta Metsola President of the European Parliament  
 
H.E. Charles Michel  
President of the European Council  
 
H.E. Ursula von der Leyen  
President of the European Commission  
 
H.E. Edita Hrdá  
Permanent Representative of the Czech Republic to the European Union Presidency of the Council of 
the European Union  
 
 
Dear Excellenci es, 
 
As developing countries responsible for a substantial share of the global output of agricultural 
products such as cattle, oil palm, soya, wood, cocoa and coffee, and as trade partners of the EU, we 
would like to express our serious concerns regarding the "Proposal for a regulation on the making 
available on the Union market as well as export from the Union of certain commodities and products 
associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 2", 
also referred to as "Proposal for a regulation on deforestation -free products ". 
 
While we agree that the fight against climate change and the conservation and sustainable 
management of forests are urgent tasks, we regret that the EU has chosen the option towards 
unilate ral legislation instead of an international engagement to deal with these shared objectives, 
reflected in the Paris Agreement and the SDGs, to which we have all subscribed.  
 
We encourage the EU to entertain further consultation with third countries, partic ularly developing 
producing countries before the final approval of the proposed legislation. Some of the concerns 
expressed by developing countries in formal public consultations about the proposed legislation 
have, regrettably, been given scarce considera tion. 
 
At present, this proposed regulation is moving quickly through the EU ordinary legislative procedure. 
It disregards the local conditions and national legislations of developing producing countries, their 
efforts to fight deforestation, and, recallin g the principle of common but differentiated 
responsibilities, also the EU Member States’ own historical role in deforestation activities and climate 
change.  
 
Although it is not the purpose of this letter to engage in detailed discussion of specific aspect s of the 
proposed regulation, a few points are the object of particular concern. Firstly, the country 
assessment criteria and benchmarking system are inherently discriminatory and punitive in nature. 
Its most likely effect will be to generate trade distort ion and diplomatic tensions, without benefits to 
the environment. Furthermore, it  imposes additional controls, entails reputational risks for 
companies and is likely to penalize producers in developing countries, especially smallholder farmers 
and SMEs.  
 
We are similarly concerned with the EU’s approach regarding several elements in the proposed 
regulation, such as the uncertain and discriminatory nature of the scope of products; definitions that 
are not multilaterally agreed; retroactive cut -off date; burd ensome due diligence mechanism and 
subjective risk assessment criteria; costly and impractical traceability and geo -localization 
requirements; and insufficient unilaterally defined transition period, which could increase costs and 
have negative social and economic consequences for developing countries. In this regard, we are 
following with attention the ongoing debate on the proposed regulation within the EU’s political 
institutions.  
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Trade restrictions or the threat thereof cannot be a preferential means to achieve environmental 
ends. We firmly believe that trade restrictions are inadequate to address environmental concerns 
and will only lead to a downward spiral of trade distortion, reduced trade opportunities and increased 
impoverishme nt, with limited if not negative effects for the conservation of forests.  
 
As developing producing countries deeply engaged in building the environmental international order 
and the multilateral trading system, we strongly believe that free trade helps rat her than hinders 
the promotion of sustainable development goals. In our view, the proposed regulation poses a 
significant challenge to fundamental WTO rules and should be brought by the EU into compliance 
with the multilateral trading system.  
 
In conclusio n, we sign this letter as a public and collective effort, supplementing the bilateral 
exchanges between our countries and the EU institutions on this matter, aimed at demonstrating 
that, from the perspective of our countries, the path chosen by the EU for combatting deforestation 
contains flaws. A better approach can be reached through cooperative means. We call upon EU 
authorities to acknowledge and take into account our concerns and look forward to a substantial, 
genuine, and constructive dialogue on the issues previously outlined before the adoption of the 
proposed regulation.  
 
Please accept, Excellencies, the assurances of our highest consideration.  
 
Sincerely yours,  
 
 
 
 
 
 
 
H.E. Pablo Ariel Grinspun  __________________  
Ambassador of  Argentina  
 
 
 
 
 
H.E. Marcos Bezerra Abbott Galvao   
Ambassador of Brazil,  
Head of t he Mission of Brazil to the European Union  
 
 
 
 
H.E. Felipe Garcia E cheverri  
Ambassador of Colombia  
 
 
 
 
H.E. Harriet Sena Siaw Boateng  
Ambassador of Ghana  
 
 
 
H.E. Jose Lambour Peñalonzo  
Ambassador of Guatemala  
 
 
H.E. Andi Hadi  
Ambassador of Indonesia  
  
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H.E. Abou Dosso  
Ambassador of Ivory Coast  
 
 
 
 
H.E. Obinna Chiedu Onowu  
Ambassador of Nigeria  
 
 
 
 
H.E. Rigoberto Gauto  
Ambassador of Paraguay  
 
 
 
H.E. Gonzalo Alfonso Gutiérrez Reinel  
Ambassador of Peru  
 
 
 
 
Ms. Viviane de Pierrefeu Midence  
CDA a.i. of Honduras  
 
 
 
H.E. Dato’ Ahmad Rozian Abd. Ghani  
Ambassador of Malaysia  
 
 
 
H.E. Xavier Aliaga   
CDA a.i. of Ecuador  
 
 
 
 
 
H.E. Valeria Denisse Vilaseca Chumacero  
Ambassador of Bolivia  
 
  
G/AG/GEN/213  
 
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  CC: 
 
Honorable Heidi Hautala  
Vice President of the European Parliament  
 
Honorable Manfred Weber  
Chairman of the European People’s Party Group  
 
Honorable Iratxe García Pérez  
Chairman of the Progressive Alliance of Socialists and Democrats Group  
 
Honorable Stéphane Séjourné President of the Renew Europe Group  
 
Honorable Ska Keller and Philippe Lamberts  
Co-Presidents of Greens/European Free Alliance Group  
 
Honorable Marco Zanni  
President of Identity and Democracy Group  
 
Honorable Raffaele Fitto & Ry szard Antoni Legutko  
Co-Chairmen of the European Conservatives and Reformists Group  
 
Honorable Manon Aubry & Martin Schirdewan Co -President of the Left Group - GUE/NGL  
 
H.E. Frans Timmermans  
Executive Vice -President for the European Green Deal  
 
H.E. Josep Borrell Fontelles  
High Representative of the European Union for Foreign Affairs and Security Policy  
 
H.E. Valdis Dombrovskis  
Commissioner for Trade and Executive Vice -President for an Economy that Works for People  
 
H.E. Janusz Wojciechowski Commissioner fo r Agriculture  
 
H.E. Virginijus Sinkevicius  
Commissioner for the Environment, Oceans and Fisheries  
 
H.E. Florika Fink -Hooijer Director General of ENVI  
  
H.E. Sabine Weyand Director General of TRADE  
 
H.E. Helena König  
Deputy Secretary General of the European External Action Service  
 
Honorable Pascal Canfin  
Chair of the Committee on the Environment, Public Health and Food Safety of the European 
Parliament  
 
Honorable Bernd Lange  
Chair of the Committee on International Trade of the European Parliament  
 
Honorable Christophe Hansen  
Rapporteur for the European Parliament Report on the Proposal for Deforestation Regulation  
 
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