SECTION|

MAY 2021

FOREST POLICY TRADE AND FINANCE INITIATIVEREPORT | MAY 2021

ILLICIT HARVEST,COMPLICIT GOODS:THE STATE OF ILLEGALDEFORESTATION FORAGRICULTURECASSIE DUMMETTARTHUR BLUNDELL
W I T H C O N T R I B U T I O N S F R O M K E R S T I N C A N B Y,MICHAEL WOLOSIN AND ESZTER BODNARii

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

Acknowledgments
This report is an update of the 2014 Forest Trends report Consumer Goods and Deforestation: An Analysisof the Extent and Nature of Illegality in Forest Conversion for Agriculture and Timber Plantations, written by
Sam Lawson, Art Blundell, Bruce Cabarle, Naomi Basik Treanor, Michael Jenkins, and Kerstin Canby.
The lead authors, Cassie Dummet and Art Blundell, with Michael Wolosin, Kerstin Canby, and Eszter Bodnar,
would like to thank all those who supported the project and made this research possible. Case study leadauthors included Gabriel Carrero (Brazil) and David Brown (Indonesia). Special thanks go to Sam Lawson forhis continued contributions to the update.
Forest Trends would also like to thank the external reviewers who generously gave of their time to enrich
this report (in alphabetical order): Tasso Azevedo, James Acworth, Melissa Blue Sky, Beto Borges, Bruce
Cabarle, Kim Carlson, Marcus Colchester, Lafcadio Cortesi, Andrew Davis, Fillipo del Gatto, Peter Dewees,
Jean-Christophe Diepart, Mike Dwyer, Ikem Eronini, David Gibbs, Alberto Gonzalez, Marcus Hardtke, Etelle
Higonnet, Khin Saw Htay, Rick Jacobson, Gabrielle Kissinger, Arnaud Labrousse, Yao Hua Law, Teckwyn Lim,
Samuel Mawutor, Sarah Milne, Giuseppe Molinario, Kim Myers, Julie Nash, Rolando Navarro, Sten Nilson,
Ruth Nogueron, Marigold Norman, Krystof Obidzinski, Marin Persson, Ivan Dario Valencia Rodriguez, MichaelRichards, Jade Saunders, Carlos Sousa, Lela Stanley, Phuc X To, Romain Taravella, Naomi Basik Treanor,
Mikaela Weisse, Dan Whyner, John Woods, Kevin Woods, and Alfredo Rodriguez Zunino. The authors alone
are responsible for any errors of fact or interpretation.
The authors are also grateful to Kevin Fertig for the collection and processing of relevant trade data, Grace
Cook and Cheyenne Coxon for keeping everyone on track, Anna Brown and Genevieve Bennett for copy
editing, and Hattie Scott for assisting in design and layout.
This study was funded by the UK Foreign, Commonwealth and Development Office (FCDO), Forest Governance,
Markets and Climate Program, and the Norwegian Climate and Forest Initiative (NICFI). The views expressedin this publication reflect those of those of the authors and do not necessarily reflect the views of funders or
external reviewers.

TABLE OF CONTENTS|

MAY 2021

Table of Contents
Acknowledgements�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������� ii
Executive Summary���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������1
1 Introduction����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������6
2 Summary of Methodology���������������������������������������������������������������������������������������������������������������������������������������������������������������������9
3 Detailed Findings��������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������13
4 Latin America and Carribean Regional Summary�����������������������������������������������������������������������������������������������������������������24
5 Africa Regional Summary��������������������������������������������������������������������������������������������������������������������������������������������������������������������32
6 Asia-Pacific Regional Summary�������������������������������������������������������������������������������������������������������������������������������������������������������39
7 Conclusion��������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������� 47
References������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������48
Acronyms���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������55
Glossary������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������56
Appendices�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������60
Appendix 1: Methodology���������������������������������������������������������������������������������������������������������������������������������������������������������������������� 60
 ppendix 2: Tropical countries by region, governance score (Forest Trends 2019),Aand date of ratification for International Labour Organization Convention 169 (ILO C169 Indigenous and Tribal Peoples Convention, 1989 [No. 169])������������������������������������������������������������������������������������������������� 68
Appendix 3: Worst-case, best evidence, and best-case estimates of percentage of forest loss
due to commercial agriculture, illegal agro-conversion, and agro-conversion linked to exports������������������������ 71
Appendix 4: Tropical forest loss and emissions due to commercial agriculture, illegal agro-conversion,and export of production linked to agro-conversion���������������������������������������������������������������������������������������������������������������� 72
Appendix 5: Amount and value of exports in 2019 linked to deforestation������������������������������������������������������������������� 74
Appendix 6: Comparison using two different global datasets��������������������������������������������������������������������������������������������� 76
Note: Country studies are contained in Annexes 1-3 as a separate document, which can be accessed at:https://www.forest-trends.org/publications/illicit-harvest-complicit-goodsiii

EXECUTIVE SUMMARY|

MAY 2021

Executive Summary
Tropical deforestation is at the root of multiple global challenges facing humanity. Achieving the Paris
Agreement’s commitment to hold climate warming to well below 2°C above pre-industrial levels requires
both rapid decarbonization of the world’s economy and rapid reduction in emissions from deforestationand other land uses. Deforestation is one of the greatest drivers of biodiversity loss. Areas of tropicalforest loss are global hotspots for zoonotic disease exposure and emergence. Access to forest land forclearance is also driving global increases in violence against indigenous peoples, local communities, andenvironmental defenders, as well as migration when communities are displaced.
While subsistence agriculture and logging still contribute to deforestation, commercial-scale agricultural
expansion is now recognized as by far the single largest driver of deforestation worldwide and thus alsoof greenhouse gas emissions from land-use change. In 2010, the Consumer Goods Forum1 resolved toachieve zero net deforestation by 2020 in four priority sectors: soy, palm oil, paper & pulp/timber, andbeef. By 2014, when the New York Declaration on Forests was signed, a wave of corporations was making
highly publicized zero deforestation commitments. The same year, Forest Trends released an analysis of
the extent to which agricultural commodities are being grown on lands that have been illegally cleared offorests (Forest Trends 2014). The results were stark: almost half of all tropical deforestation between 2000
and 2012 was driven by the illegal conversion of forest lands for commercial agriculture, and half of the
production from this agro-conversion was destined for export markets.
Today, the 2020 target year for achieving net zero commodity-driven deforestation has come and gone.
A decade-long surge of voluntary corporate commitments has been unable to stem the tide of global
forest loss. Clearing for commercial agriculture has continued and is, in fact, getting worse.
After more than a year of intense global focus on the COVID-19 pandemic, policy makers are beginningto emerge from the fog to face problems too long ignored. An urgent need to focus on near-term economic
recovery threatens to sideline longer-term objectives in many countries. But global greenhouse gas
emissions, after falling more than 6 percent in 2020 from a massive drop in travel and economic activity,
already appear to be roaring back. Meanwhile scientific evidence attesting to the need for aggressive
global climate action and biodiversity protection continues to roll in.
To combat further forest loss, the European Commission (EC), United Kingdom (UK), and United States(US) are all considering legislation or other trade measures that would prohibit the import of commodities
grown on deforested land. There is a strong interest to know to what extent legislation based on thelegality of the imported agricultural commodity would address broader deforestation. It is also important
to clarify how donor and consumer nations can best support producer countries, industry, and otherstakeholders to uphold national laws and regulations when it comes to the conversion of forested lands
for agriculture.
1CEO-level organization of 400 global consumer goods manufacturers and retailers with a combined revenue of more than
US$2.8 trillion (2.1 trillion Euros).

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

Several initiatives have quantified how
much and where deforestation is driven
by commercial agriculture, and even
how much of this deforestation was
driven by international trade. However,fewer analyses have been able todetermine the extent to which
agricultural commodities are being
grown on lands that have been illegally
cleared of forests. This study therefore
focuses on illegal deforestation driven
by agricultural expansion, and places
it within the scope and scale of all
tropical deforestation. Forest Trends
progressively walks readers throughassessments of:Defining “illegal deforestation”
This report defines illegal deforestation as forest clearing
in violation of a producer country’s legislative framework(e.g., their laws and regulations) at the time the deforestation
took place. The analysis focused only on material violations,specifically on illegalities in licensing (e.g., failures to obtain
permits or permission from landowners, conduct
environmental impact assessments, corrupt and fraudulent
authorizations, etc.) and on forest clearance (overharvesting,outside of boundaries, tax evasion, etc.). Breaches ofinternational law or customary law are not included unlessthey are integrated into national legislation.

● deforestation writ large, all of which is of concern for its impacts on climate, biodiversity, and people;● agro-conversion because it is the largest driver of permanent forest loss across the tropics;● illegal agro-conversion because it is particularly egregious in its contravention of rights and sharedcommunity values as expressed through sovereign law and regulation; and,● agro-conversion for export because the actors involved in these supply chains stretch around theglobe, and consumers around the world share some culpability for deforestation.
This report revisits Forest Trends’ 2014 report, by reassessing the extent of illegal agro-conversion acrossthe tropics from 2013 to 2019, and finds a similar story: more forest land is being illegally cleared to makeway for agricultural crops and pastures than ever before.

KEY FINDINGS: GETTING AN ACCURATE PICTURE
This report finds that almost two-thirds (60 percent) of tropical forest loss was driven by commercial
agriculture between 2013 and 2019. Almost three-quarters (69 percent) of this agro-conversion was
conducted in violation of national laws and regulations (Figure 1). In fact, the rate of illegal deforestation
during this period increased by 28 percent compared to 2000 to 2012: from 3.5 million hectares (Mha)per year to 4.5 Mha per year. These estimates of illegal deforestation are likely an underestimate because
many countries have only limited data on which to assess illegality. Thorough audits rarely happen. Thusan absence of evidence of illegality should not be taken as evidence of compliance with laws andregulations.

EXECUTIVE SUMMARY|

MAY 2021

Figure 1 | Area of tropical forest loss (million hectares; Mha) driven by commercial agriculture, and estimates of
how much loss was illegal (%) and exported (%), 2013-2019
At least 69%

Illegal

32 MhaTotal tropicalforest loss
2013-1977 Mha...of which
60% was due
to commercial
agriculture

46.1 Mha

31%

69%

exporteddomestic
consumption

Key findings of this report include:
1. 77 Mha of tropical forests were lost between 2013 and 20192: the equivalent of clearing more than
five Manhattans every day for seven years. During this time, average annual tropical forest loss surged
to more than 11 Mha per year, compared to 7.3 Mha per year in the first 12 years of the 21st century – anincrease of 52 percent. Brazil, Indonesia, and the Democratic Republic of Congo (DRC) together
accounted for 51 percent of all tropical forest loss between 2013 and 2019. All three have seen increases
in average annual loss (by 14 percent, 17 percent, and 162 percent, respectively) during this time.
2. Almost two-thirds (60 percent) of tropical deforestation between 2013 and 2019 was driven bycommercial agriculture. Commercial agriculture was the primary identifiable driver of forest loss
everywhere except Africa, where subsistence agriculture reportedly drove almost all deforestation.
More than 6.58 Mha of tropical forests were cleared each year to make way for commercial agriculturaloperations. This represents an increase of 28 percent in the average annual scale of agro-conversion
as compared to 2000 to 2012.
3. At least 69 percent of agro-conversion was conducted in violation of national laws and regulations,and this is likely an underestimate. Illegal agro-conversion was responsible for at least 31.7 Mha of
the total 77 Mha of tropical forest loss between 2013 and 2019 (Figure 2) – an area roughly the size of
Norway. This equates to an average annual loss of more than 4.5 Mha per year, an increase of 28
percent from the 2000 to 2012 period (3.5 Mha per year). Illegal activities were narrowly defined as
only those of material import, such as obtaining land illegally, clearing in excess of permits, fraud andcorruption, human rights abuses, and breaches of environmental law.
These estimates are considered conservative. In countries where governance is weak and corruption
widespread, the lack of evidence of illegality is typically not an indication that the agro-conversion isin compliance, but an indication that more reporting is required. Where comprehensive compliance
audits do exist, evidence of illegal deforestation is widespread. For example, in Brazil, at least 95 percent
of all deforestation was illegal. Similarly, Indonesia’s Supreme Audit Agency found less than 20 percent
of palm oil operations in compliance with national laws and regulations.
	Global Forest Watch. 2020. “Tree cover loss by dominant driver.” Time range selected: 2001-2019, using methods from Curtis
et al. 2018. Washington DC, USA: Global Forest Watch, World Resources Institute. www.globalforestwatch.org.

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

4

Figure 2 | Proportion of agro-conversion in violation of national laws and regulations (minimum estimate),2013-20193
1

3

3 2
2 2 3

32 2
2

1
2

3
2

3

1

1

1

2

2

3

2

Total forest loss
Minimum extent of illegal agro-conversion:
75-100% 50-74% 25-49% 0-24%

Availability of data on legality:
1 = high 2 = medium 3 = low

4. Soy, palm oil, and cattle products drive global figures of illegal deforestation, but other smaller-scalecommodities, such as cocoa, rubber, coffee, and maize, are also leading causes of illegal deforestation
in some regions, with devastating effect. Identifiable illegal deforestation is pervasive in the expansionof croplands for soy (93 percent of agro-conversion across all soy-growing countries in this study), cocoa(93 percent), and cattle products (beef at 81 percent and leather at 87 percent). The global average
proportion of illegality for palm oil (59 percent) is constrained by low data availability in Malaysia, although
81 percent of clearing for Indonesia’s palm oil is estimated to be illegal. Global estimates for commodities
like rubber, coffee, and maize are limited by data availability, but are still high enough to show significant
issues with legal compliance. The country case studies that accompany this report detail coffee andcocoa production expanding into protected areas in Honduras and West Africa; in Argentina, maize is
the leading driver of deforestation, of which at least 65 percent is in contravention of land zoning laws.
5. Emissions from illegal ago-conversion account for at least 42 percent of all emissions from tropicaldeforestation. Illegal agro-conversion was likely responsible for at least 2.7 gigatons (Gt) of carbondioxide equivalent (CO2e) per year, and 19 Gt of CO2e between 2013 and 2019. On an annual basis, that’smore than India’s emissions from fossil fuels in 2019, and if illegal agro-conversion were a country, itsemissions would be third-largest after China and the US. The largest producer of emissions from illegal
agro-conversion was Latin America (13.7 Gt), mainly due to massive forest loss in Brazil associated withfires over the last few years.
6. More than 31 percent of agricultural commodities linked to deforestation were exported, raising
significant concerns about their association with illegal deforestation. In 2019, exports of ten agriculturalcommodities valued at US$55 billion were linked to agro-conversion – mostly those grown in Latin
America and Asia. This trade represents emissions of at least 1.2 Gt CO2e per year from more than 14
Mha of forest land cleared between 2013 and 2019.
3

Figure 2 represents only the 23 countries assessed in this study, which together account for 87 percent of global tropicalforest loss.

EXECUTIVE SUMMARY|

MAY 2021

It is not possible to calculate at a global level precisely what share of illegally produced commodities
are ultimately exported from their country of origin. This report examines 23 case study countries andfinds at least one-fifth – and in some cases virtually all – of agricultural exports were linked to illegal
deforestation, depending on the commodity and country of origin. Given the evidence available, the risk
is non-negligible and must be assumed to be high for widely traded commodities like soy and palm oil.
7. Deforestation for agro-commodity production that is driven by export demand varies, but has
increased overall since 2013, which will affect the potential impact of consumer and demand-side
measures. However, the proportion of production linked to agro-conversion that is then exported has
declined from 49 percent in the 2000 to 2012 period to 31 percent since 2013. This is because in somecountries, deforestation is not driven by commercial agriculture (DRC, Madagascar, Sierra Leone) or theiragricultural products are not destined for export (Colombia, Bolivia, Mexico). In these countries especially,
demand-side measures such as corporate purchasing policies or import regulations will be less effective
than programs which strengthen domestic governance; programs for sustainable management of theland and forest sectors must take leading roles.
Demand-side measures, however, will be effective when a high proportion of deforestation for agrocommodity production is being driven by export demand, as is the case for example in Indonesia,
Malaysia, and Laos. However, agro-exports are increasingly headed to markets in China and India, where
regulatory and consumer pressures for environmental protections are lower. If demand-side regulatory
measures are only adopted in some major markets (such as the US, Europe, and Australia) but not inothers, a bifurcation of trade is likely, with high-risk commodities continuing to find buyers in importmarkets without legislation or trade measures blocking illicit goods.

CONCLUSION
Even in the face of shortcomings in producer country monitoring and reporting (in particular, a lack ofrigorous auditing), the evidence presented in this report reveals that illegal agro-conversion and thesubsequent illegality of associated agricultural commodities remains an immense problem that has beengetting worse. This report reveals the ugly truth: that much of global agribusiness trade is linked to operations
that illegally clear forests.
While the findings of this report seem dire, there is hope. Brazil was successful in drastically reducing
deforestation up until 2012 – and in doing so contributed more to addressing climate change through areduction in related emissions than any other single country. Indonesia has successfully reduced its
deforestation every year since a peak in 2016. Forest Trends observes continued leadership from somecorners of industry. There is increasing global political focus on natural climate solutions, including legislation
addressing the imports of agricultural products associated with deforestation – either legal or illegal – now
being developed by the EC, UK, and US.
In a forthcoming report, Forest Trends will propose a path forward for curbing illegal land-use change andadvancing forest country objectives for zero deforestation. In the meantime, this report shows that too
much of the world’s agricultural production and trade carries a high risk of including illicit harvests, leaving
companies and their customers complicit in tropical forest loss and trafficking in illegal products.

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

61Introduction

This report assesses the scope and scale of illegal deforestation in the tropics that has been driven bycommercial agriculture. Numerous reports in the past decade have demonstrated how commercial-scale
agricultural expansion is by far the single largest driver of deforestation worldwide and thus also ofgreenhouse gas emissions from land-use change. There have also been analyses on how much of thisdeforestation was driven by consumer demand from around the world. Fewer analyses, however, havefocused on the extent to which agricultural commodities are being grown on lands that have been illegally
cleared of forests – in violation of a country’s own national laws and regulations.
This report places illegal deforestation within the scope and scale of all tropical deforestation, andprogressively walks readers through assessments of:● deforestation writ large, all of which is of concern for its impacts on climate, biodiversity, and people;● agro-conversion because it is the largest driver of permanent forest loss across the tropics;● illegal agro-conversion because it is particularly egregious in its contravention of rights and sharedcommunity values as expressed through sovereign law and regulation; and,● agro-conversion for export because the actors involved in these supply chains stretch around theglobe, and consumers around the world share some culpability for deforestation.
In 2010, the Consumer Goods Forum4 resolved to achieve zero net deforestation by 2020 in four priority
sectors: soy, palm oil, paper & pulp/timber, and beef. By 2014, when the New York Declaration on Forests
was signed, a wave of corporations was making highly publicized zero deforestation commitments. The
same year, Forest Trends released an analysis of the extent to which agricultural commodities around theworld were being grown on illegally deforested land (Forest Trends 2014). The results were stark: almost
half (49 percent) of all tropical deforestation between 2000 and 2012 was driven by illegal conversion offorest lands for commercial agriculture, and half of the production from this agro-conversion (50 percent)was destined for export markets.
Today, the 2020 target year for achieving
net zero commodity-driven deforestation
has come and gone. A decade-longsurge of voluntary corporate commitments
in Europe and the US was unable to stem
the tide of global forest loss, despite
concerted effort on the part of leading
companies and an extensive network ofefforts supporting the strategy.
4

Illegal deforestation
Conversion of forests that takes place in contravention ofa country’s legislative framework (e.g., their laws andregulations) at the time the deforestation took place.
Breaches of international or customary law were notincluded unless they are integrated into national legislation.

CEO-level organization of 400 global consumer goods manufacturers and retailers with a combined revenue of more than
US$2.8 trillion (2.1 trillion Euros).

INTRODUCTION|

MAY 2021

This study confirms what was revealed in 2014 – that the phenomenon of illegal forest clearing forcommercial agriculture has continued at an alarming rate and is, in fact, getting worse. Agricultural products
harvested from these lands are destined for markets around the world, tainting international supply chainswith illegality.
While some geographies have made progress, others have experienced backsliding. To date, the overall
picture is that reaching zero agro-conversion is getting harder, not easier. The average annual rate oftropical forest loss increased from about 7.3 Mha per year in the first 12 years of this century, to 11 Mha peryear since then (GFW 2020, using Hansen et al. 2013). Forest Trends found that 60 percent of this tropicalforest loss (6.6 Mha per year) was driven by commercial agriculture, an increase of more than 28 percent
in the average annual scale of agro-conversion as compared to 2000 to 2012 (5.1 Mha per year), eventhough the proportion of deforestation attributable to agro-conversion decreased somewhat from 71
percent (Forest Trends 2014). Likewise, at least 69 percent of agro-conversion from 2013 to 2019 (4.5
Mha per year) was conducted in violation of national laws and regulations, an increase of 28 percent
over the average annual rate from 2000 to 2012 (from 3.5 Mha per year), despite a slight decrease in the
proportion of illegal conversion (from at least 49 percent to at least 41 percent of all tropical forest loss).
All is not lost, however. There are proof points around the world that give glimmers of hope. Brazil madeimmense progress reducing deforestation from a peak in 2004 to 2012 through a combination of politicalleadership, legal enforcement, rural credit restrictions for farmers, and voluntary industry self-regulation– although the last few years of backsliding remind the world that lasting transformation will require muchbroader and deeper domestic political agreement (see Annex 1). The Government of Norway and the UN
Green Climate Fund (in its largest payment to date) paid the Government of Indonesia US$160 million incompensation for reducing emissions from deforestation starting in 2014. It is clear that the country’s
multi-year effort to protect and restore peat lands, and international support for this and other programs,
have been positive factors. However, like Brazil, these gains are at risk of being undermined if, for example,
Indonesia tries to boost economic activity at the expense of forests and peatlands under its COVID-19
response. There are also early signs that cocoa-driven deforestation in West Africa may have reached atipping point, with major cocoa traders banding together and leading the call in Europe for increased
action and regulation.
To stem further forest loss, the European Commission (EC), United Kingdom (UK), and United States (US)are all considering legislation or other trade measures that would prohibit the import of commodities grownon illegally converted land. There is a strong interest to know to what extent legislation based on thelegality of the agricultural commodity would address broader deforestation, and how donor and consumer
nations can support producer countries, industry, and stakeholders to uphold national laws and regulations
when it comes to the conversion of forested lands to agricultural fields.
These stories are good reminders that successful governance and rule of law in the land sector are hardwon but possible on national scales. In a forthcoming report, Forest Trends will propose a path forward
for curbing illegal land-use change and advancing forest country objectives for zero deforestation. The
following sections outline the current situation by region including the extent of deforestation, how muchis driven by agro-conversion, how much of that conversion is illegal, and how much resulting product isexported. Country-level analysis is provided in Annexes 1-3.

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

Key Definitions
Full list can be found in the Glossary, p. 56

Agro-commodities: Commercially produced agricultural commodities, including crops, livestock,and products from tree plantations.
Agro-conversion: Loss of forest driven by commercial agriculture.
Commercial agriculture: Large- or small-scale, including crops, pasture (mainly cattle), and monoculture
tree plantations. Excludes subsistence farming.
Forest/Forest cover: Forest areas with greater than 50 percent tree cover that are greater than
five meters tall.
Forest loss/Deforestation: Complete removal of forest cover (areas with at least 51 percent of tree
cover).

SUMMARY OF METHODOLOGY2|

MAY 2021

Summary of Methodology

This study estimates illegal deforestation for purposes of commercial agriculture in the tropics, andassociated exports of key agricultural commodities from 2013 to 2019. A more detailed description of
methodology and data used can be found in Appendices 1 through 6.

PART 1
Estimating illegal deforestation for commercial agriculture andassociated trade
To estimate tropical deforestation driven by the illegal clearing of forest lands for commercial agriculture andthen calculate associated trade of agricultural commodities, Forest Trends followed the following steps:

Step 1: Estimating tropical forest loss, 2013-2019 (Variable A)
The amount of forest loss for each tropical country was obtained from the Global Forest Watch (GFW 2020,
using Hansen et al. 2013) database of annual change in tree cover between 2013 and 2019, inclusive for
all forests with greater than 50 percent canopy cover – primary as well as secondary forests and plantations.
Plantations were 8 percent of all forest loss over this period.

Step 2: Estimating percentage of tropical forest loss linked to commercial agriculture(Variable B)
The study used the GFW (2020) database, which uses the methodology of Curtis et al. (2018) for driversof forest loss in each country. However, for the countries most affected by deforestation, Forest Trends
conducted 23 country studies (Annexes 1-3). The remaining 101 countries comprise the “rest of the world”
and account for only 13 percent of all tropical forest loss. Key sources of information include national REDD+
reporting and Pendrill et al. (2019, updated with data to 2017). In particular, Forest Trends focused on therole of commercial agriculture driving tropical forest loss between 2013 and 2019, which includes all major
crops, cattle, and forestry products from tree plantations.

Step 3: Estimating percentage of forest conversion driven by commercial agriculturethat was likely illegal (Variable C)
In this report, legality is framed in the context of recognizing each country’s sovereign rights. “Illegality” istherefore defined as the conversion of forests that takes place in contravention of a country’s legislative
framework, including its laws, regulations, instructions, and any other legal instrument that penalizes noncompliance (Box 1). International treaties are not included in this definition unless they have been incorporated
into national law. For each of the country studies, the literature was reviewed to evaluate compliance offorest clearing (agro-conversion) against the relevant legislative framework at the time the deforestation
took place.

9

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

10

BOX 1

Typology of Illegalities in the Conversion of Forests
for Commercial Agriculture
This report defines illegal deforestation as forest clearing in violation of the producer country’s own
laws and regulations at the time the deforestation took place. The methodology focuses only onmaterial violations (those that are substantial and most serious), specially on violations occurring during
the licensing and forest clearing processes. Breaches of international law or customary law are notincluded unless integrated into national legislation. Typical examples include:
Non-compliance with licensing or permit processes:■ Failure to consult communities affected by commercial operations■ Lacking the consent of landowners■ Forced relocation of local communities without compensation■ Allocated in areas zoned for permanent forest cover (e.g., protected areas, forest estates where
only sustainable forest management is permitted)■ Failure to obtain regulatory approval (e.g., lacking socio-/environmental impact assessments, failingto produce pre-qualification requirements)■ Failure to post performance bonds■ Concessions allocated in excess of the limits on total area for an individual/company
Non-compliance with harvesting or land clearance requirements:■ Clearance prior to obtaining appropriate permits■ Clearance without consent and/or compensation of affected communities■ Illegal use of fire
■ Failure to pay taxes and fees, including on timber extracted during conversion■ Clearance of forest outside boundaries of license area
■ Pollution of waterways with, for example, logging debris■ Failure to comply with regulations (e.g., related to road construction and culvert/bridge design tominimize erosion)■ Felling of protected tree species■ Clearance of forest in prohibited zones within concession area, including steep slopes, river buffer
areas, and deep peat soils■ Clearing in excess of maximum proportion of the concession area permitted
Corruption at any stage of these processes:■ Licenses issued improperly and/or at below market value in exchange for bribes■ Rights obtained through fraud, coercion, or other illegal means■ Monitoring and enforcement reductions in exchange for bribes■ Failure to pay royalties on timber harvested, fees, and/or taxes

SUMMARY OF METHODOLOGY|MAY 2021

Step 4: Calculating forest loss driven by agro-commodities linked to illegal conversion
For the 23 countries that comprised 87 percent of all tropical forest loss, Forest Trends used the casestudies (Annexes 1-3) to derive best estimates of Variables A, B, and C. For the “rest of the world,” Forest
Trends used GFW (2020) data for each country (Variables A and B), and the regional average for Variable
C (Africa, Asia, or Latin America). The product of these variables provides a best estimate of the area of
tropical forest lost to agro-commodities linked to illegal conversion for each country (Equation 1). To test
the implication of using regional averages for Variable C for the “rest of the world,” Forest Trends conducteda sensitivity analysis by substituting a “best case scenario,” where all agro-clearing was assumed to belegal and a “worst case scenario,” where all the agro-conversion was assumed to be illegal (Appendix 3).
Given that the 101 countries in the “rest of the world” comprised only 13 percent of tropical deforestation,
it was assumed that global results would not vary too widely among the three scenarios. This sensitivity
analysis also allowed Forest Trends to examine the impact of having to use regional averages for sevenof the case study countries that lacked sufficient data on compliance (Variable C).
Equation 1: Formula used to calculate area of tropical forest loss due to illegal conversion for commercial
agriculture, 2013-2019
Tropical forest
loss, 2013-2019
(Mha)

A

% of loss driven
by commercial
agricultureB% of loss
likely illegal

C

Area of tropicalforest loss due
to illegal
commercial
agriculture(Mha)

Step 5: Percentage of agro-commodities linked to deforestation and exported (Variable D)
The primary source of data for Variable D was the Pendrill et al. (2020) analysis of embodied deforestationand country of consumption. For commodity-specific analysis in each country study, the proportion of
production exported was calculated with production data from the United Nations Food & Agriculture
Organization (UN FAO) and trade data from the UN’s International Trade Statistics Database (UN Comtrade).
Where a country produced more than one export commodity, the amount of deforestation embedded in
the trade was weighted by the size of each commodities’ trade and its link to deforestation.

Step 6: Calculating tropical forest loss driven by agro-commodities for export
The product of Variables A, B, and D provides Forest Trends’ best estimate of the area of tropical forest
lost due to agro-commodity production for export markets (Equation 2).
Equation 2: Formula used to calculate tropical forest loss driven by exported agro-commodities, 2013-2019
Tropical forest
loss, 2013-2019
(Mha)

A

% of loss driven
by commercial
agricultureB% of loss thatwas exportedD

Tropical forest
loss due to agroconversion forexport (Mha)11

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

12

Step 7: Estimating emissions from agro-commodity conversion (Variable E)
This report estimated the amount of carbon dioxide-equivalent (CO2e) emissions from forest loss using
analyses by Harris et al. (2021).

PART 2Estimating the quantity and value of exports from converted forestland
Forest Trends estimated the quantity and value of exports in 2019 for specific agricultural commodities
that originated from converted forestland: beef and leather, palm oil, soy, pulp and paper, rubber, cocoa,
coffee, and maize. Deforestation linked to this trade was tracked in the focus 23 countries over the last
30 years (since ~1990), not just on land cleared of forests since 2013. To calculate the amount of tropicalforest loss embodied in exports and the risk of contamination by illegal deforestation, the following steps
were taken:

Step 1: Estimating quantity and value of exports (Variable F)
For each relevant commodity and country, 2019 trade data was obtained from UN Comtrade and relevant
literature, where available.

Step 2: Estimating percentage of production coming from agro-conversion (Variable G)
The proportion of production for each commodity that originated from land cleared of forest was obtained
from a literature review. Estimates of deforestation between 1990 and 2013 were obtained from Forest
Trends (2014).

Step 3: Estimating the risk of agro-commodity contamination by illegal agro-conversion
Illegality was evaluated for the deforestation associated with the commercial agricultural commodities(Variable C). When production of a commodity is widespread across the country, Variable C (the estimateof illegality used above) was used. When a commodity is grown in a specific region (such as Paraguayan
soy grown in the eastern Atlantic Forest region that has a Zero Deforestation Law) then the illegality
estimate is commodity specific. Forest Trends (2014) and other literature provided estimates of illegality
for land cleared prior to 2013.

Step 4: Calculating total volume of exports linked to deforestation
The product of Variables F and G provides Forest Trends’ best estimate of the total volume of exported
commodities that was likely contaminated by its link to deforestation.
Equation 3: Formula used to calculate tropical forest loss embodied in agro-commodity exports,
2013-2019For each commodity, for each major producing country
Total volume orvalue of exports(tonnes or US$)F

% of production
from land
converted fromforests since 2000

G

Total volume orvalue of exports
linked to
deforestation(tonnes or US$)DETAILED FINDINGS3|

MAY 2021

Detailed Findings

To tackle deforestation, the following fundamental questions need to be understood: where are the forests
being lost, and what activities are driving this forest loss? This allows for targeted efforts and specificrecommendations on how to approach specific industries, products, or countries where they will have thegreatest impact. For example, tools to tackle illegal deforestation will be entirely different than thoseneeded to combat broader deforestation.
Several initiatives have quantified how much and where deforestation is driven by commercial agriculture.
Some have gone as far as to estimate how much of this deforestation was driven by international trade.
Global Forest Watch publishes annual data on forest loss based on the methodology of Hansen et al.
(2013) and the drivers of that loss, including commodity-driven agriculture, based on Curtis et al. (2018)
and FAO’s Global Forest Resources Assessment reports.5 In a study published in Global Environmental
Change, Florence Pendrill and colleagues (2019) addressed both agro-conversion driven deforestationand connected it to global trade drivers. They quantified how much and where deforestation occurredfrom the expansion of croplands, pasture, and tree plantations, and identified which products were grownon this converted land. They then integrated their results with global trade flow data to assess how muchdeforestation was likely driven by international trade.
However, fewer analyses have been able to determine the extent to which agricultural commodities are being
grown on lands that have been illegally cleared of forests. This study focuses on illegal deforestation driven
by commercial agriculture, and places it within the context and scale of all deforestation across the tropics.

Figure 1 | Area of tropical forest loss (million hectares; Mha) driven by commercial agriculture, and estimates of
how much loss was illegal (%) and exported (%), 2013-2019

At least 69%

Illegal

32 MhaTotal tropicalforest loss
2013-1977 Mha5...of which
60% was due
to commercial
agriculture

46.1 Mha

31%

69%

exporteddomestic
consumption

FAO’s Global Forest Resources Assessment documents how the world’s forests are changing. The reports are released every
five years.

13

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

14

The rate of deforestation across the tropics has been increasing.
Over the past seven years, the world has lost, on average, more than 10.9 Mha of tropical forest each year.
In total, this equals approximately 77 Mha lost (Figure 1), or an area 1.5 times the size of France. This deforestation
rate is 52 percent higher than the average losses of 7.2 Mha per year reported by Forest Trends (2014) from2000 to 2012.
Brazil, Indonesia, and the Democratic Republic of Congo (DRC) have the largest areas of tropical forest in
their respective regions and alone account for more than half (51 percent) of all forest loss in the tropics from2013 to 2019. Therefore, addressing deforestation in these three countries will be key to addressing local
challenges, such as livelihood and food security, as well as global challenges such as climate change. Country
analyses (Annex 1–3) suggest that all
three continue to suffer from highIn this report, Forest Trends defines “forests” as thoseannual rates of deforestation and,lands with more than half of their area covered by vegetation
more significantly, their averagetaller than five meters. Setting a high threshold of greater
annual forest loss has continued tothan 50 percent tree cover focused the analysis on wellrise (by 14 percent, 17 percent, andforested landscapes, such as primary forests, that still provide
162 percent, respectively, since therobust ecosystem services (e.g., supporting well-functioning
initial Forest Trends study assessing
6
the years 2000 to 2012 ). Whilepollination, water and nutrient cycles, and carbon sinks).
targeting Brazil, Indonesia, and DRC“Deforestation” and “forest loss” are defined as the complete
will be strategic pressure points inand permanent loss of trees in a forested area. This reportaddressing deforestation on a global
covers all forest types found in tropical countries, including
scale, it is just as critical to maketropical rainforests, the dry forests of the Brazilian Cerrado,
progress in the other countries thatand the Gran Chaco of South America.
make up the remaining 49 percent
7of tropical forest loss.

The rate of tropical deforestation driven by commercial agriculture isincreasing in the tropics.
Agro-conversion, where areas of forests are cleared or burned to make way for crops or livestock, is thenumber one driver of tropical deforestation worldwide. As demand for land for commercial agriculture rises
and falls, so does overall deforestation in the tropics.
Forest Trends estimates that more than 46 Mha – almost two-thirds (60 percent) of all tropical deforestation– was driven by commercial agriculture between 2013 and 2019 (Figure 1). This loss was equivalent to morethan 23 football fields every minute over the last seven years. More significantly, this agro-conversion continues
to increase, despite years of pledges by companies to help reduce deforestation. More than 6.5 Mha oftropical forests were cleared each year, representing an increase of 28 percent (as compared to 2000 to
2012, when the average annual loss stood at 5.1 Mha).

6
7

Although a change to Global Forest Watch’s methodology in 2012 confounds these results (Potapov et al. 2015).
Individually, other countries’ deforestation may not have a large profile for global issues such as climate change, but local and regional ecosystem impacts can negatively affect livelihoods, displacement of communities, biodiversity, flood protection and evenabilities to control the emergence of zoonotic disease – which can subsequently trigger impacts at regional or global scales.

DETAILED FINDINGS|

MAY 2021

Figure 2 | Total tropical forest loss, 2013-2019

Total forest loss

Domestic consumption

Total loss due to agro-conversion

Exported agro-conversion

Notes: Calculations by Forest Trends.

These losses were not spread equally across the tropics. Overall, just two countries, Brazil and Indonesia,
were responsible for almost two-thirds of all reported global agro-conversion, 39 percent and 20 percent
respectively (Figure 2). About three-quarters of forest loss in Asia and Latin America was reportedly driven
by commercial agriculture (more than 18 Mha and 26 Mha, respectively). Brazil is not alone in Latin America
in reporting a rising rate of forest loss due to commercial agriculture; the same is occurring across most oftropical Latin America. For example, deforestation in Colombia has increased in areas previously isolated
by civil war, and the Gran Chaco dry forests have experienced intensive conversion.

Figure 3 | Regional tropical forest loss (millions of hectares; Mha) driven by commercial agriculture and the main
contributing country, 2013-2019

Millions of hectares

40
30
20
10
0

Latin America& Caribbean

BrazilAsia-PacificIndonesia

Agro-conversion

Other

AfricaDemocratic
Republicof Congo

Notes: Calculations by Forest Trends.

In contrast to most of the tropical world, commercial agriculture was not the primary identifiable driver offorest loss in Africa. Here, one-quarter of global tropical forest loss occurred, but only 10 percent of it was

15

16

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

reportedly due to agro-conversion (Figure 3). Extensive logging roads open the forest for subsistence
agriculture, the driver for almost all deforestation according to Global Forest Watch (2020, using Curtis et al.
2018). Monitoring the causes of deforestation in Africa can be challenging, however, given the difficulty
discerning small-holder commercial agriculture plots from subsistence agriculture, and the fact that several
common commodities grown in Africa, such as cocoa and coffee, are often grown under shade tree cover(and thus difficult to analyze with satellite imagery). Yet, at a time when yields are reportedly decreasing in
Africa, Forest Trends found that as cocoa bean production increased by roughly 50 percent in Côte d’Ivoire
and Ghana between 2010 and 2018, so did the area of land used to grow cocoa. Area (ha) of land undercocoa production in Côte d’Ivoire increased by 76 percent, while Ghana increased cocoa production areaby 12 percent.
Across the globe in all regions, interrelated direct and indirect drivers of deforestation make a comprehensive
understanding of the situation difficult. Subsistence farmers are often blamed for deforestation, but industrial
forestry and the logging roads built to facilitate it often precedes forest clearing, indicating that the timber
sector shares responsibility, albeit indirectly, for much of the deforestation. Efforts to give land titles to thepoor or policies that allow settlers to claim title for productive land are also leading to forest loss. In Vietnam,
the indigenous people of the Central Highlands are displaced by government-sponsored migrants who
move to the hills and expand agriculture, pushing the indigenous ethnic groups into the forest where theyclear trees – possibly illegally – for small-scale agriculture. In other places, boom and bust cycles of largescale agricultural commodities lead to an ever-expanding list of commodities driving the rapid expansion ofcrops into forested areas.
In other countries, loopholes in the law, agricultural permits, as well as fraudulent land claims and land speculation
are leading to forest clearing. Agricultural permits are sometimes used as a short cut to access valuable timber,with no intention to establish crops after the timber harvest. For example, in Colombia, two-thirds of forest loss
is reportedly land grabbing under the guise of conversion for pasture (Minambiente 2017). In Cambodia, Economic
Land Concessions have been described as “mechanisms for the ruling elite to enable land grabbing...andselling of high value timber” (Beauchamp et al. 2018). In Papua New Guinea, it is the value of the timber driving
the agro-conversion; timber exports from illegal clearance conducted under agricultural permits account for
63 percent of all timber exports (Global Witness 2017; 2018a; 2020; Filer 2020). All these processes are partof the complex pattern of land-use change where forest loss intersects with agriculture.

The rate of illegal deforestation for commercial agriculture is also
increasing across the tropics.
At least 69 percent of all agro-conversion in the tropics was the result of illegal deforestation (Figure 4). For
purposes of this report, Forest Trends focused only on material violations, specifically on illegalities in licensing(e.g., failures to obtain permits or permission from landowners, conduct environmental impact assessments,
corrupt and fraudulent authorizations, etc.), forest clearance (overharvesting, outside of boundaries, tax
evasion, etc.), or incidences of fraud and corruption. Breaches of international law or customary law are notincluded unless they are integrated into national legislation.
Overall, illegal agro-conversion was responsible for the loss of at least 31.7 Mha of the total 77 Mha of tropicalforest loss between 2013 and 2019 – an area roughly the size of Norway. This appears to be an increaseover the amount of illegal deforestation driven by commercial agriculture that was reported in the Forest
Trends (2014) report: from 3.5 Mha per year between 2000 and 2012, to 4.5 Mha per year, an increase of
more than 28 percent.

DETAILED FINDINGS|

MAY 2021

Figure 4 | Proportion of agro-conversion in violation of national laws and regulations (minimum estimate),2013-20198

1

Minimum
extent ofillegal agroconversion:

3

32

1
2

75-100%50-74%
25-49%
0-24%

3
2

1

3 2
2 2 3

2

2

3

1
3

2

2

1

2

Availability of data on legality:
1 = high 2 = medium 3 = low

Grey circles = total forest loss
Color circles = total loss due to agro-conversion

Notes: Calculations by Forest Trends.

Even more disconcerting is the fact that this estimate of illegal agro-conversion is conservative. It is only
possible to evaluate compliance if robust reviews (or audits) have been completed for at least a representative(randomly selected) portion of the sector. For purposes of this report, Forest Trends is only reporting
estimates of well-documented illegality. While published case studies of illegal deforestation occurring on
specific plantations or operations suggest that non-compliance is widespread, Forest Trends could not use
these reports to scale up estimates for the entire sector, or for the entire country.
For eleven of 23 case studies, representing just over about one-third of all tropical agro-conversion, thecountries have not conducted and reported comprehensive audits, meaning Forest Trends was unable to
make sector-wide estimates of illegality. Therefore, these eleven assessments are necessarily conservative,
and likely underestimates. Where such compliance audits have not been conducted, an absence ofevidence must not be misconstrued as evidence of an absence of illegality.
In the five countries (Brazil, Mexico, Argentina, Madagascar, and DRC, representing almost half of all agroconversion) where there has been reliable reporting of nation-wide levels of compliance, the rate of illegality
is extreme. For example, in Brazil, compliance can be adjudged for the entire commercial agriculture sector,
made possible by the Environmental Rural Registry (CAR) database and an ability to match private property
boundaries with forest loss data, Forest Code rules, and deforestation. This evidence indicates that virtuallyall (at least 95 percent) operations that cleared forests in Brazil are not in compliance with the laws governing
forest clearing. In 2019, forest clearing was 99.5 percent illegal (Rezende de Azevedo et al. 2019). Mexico
requires authorization for agro-conversion from the Ministry of the Environment and Natural Resources, anda study of the period 2005 to 2015 identified that less than 3 percent of forest loss had been authorized
8

Figure 4 represents only the 23 countries assessed in this study, which together account for 87 percent of global tropicalforest loss.

17

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

18(Beraud-Macías et al. 2018). Argentina’s Forest Law of 2007 requires land to be zoned based on its conservation
value. However, a Greenpeace Argentina (2018) study concluded that deforestation in zones where clearing
is not permitted was 50 percent of all deforestation, and a further 15 percent was on land that had not been
zoned at all. In Madagascar, all forest clearance for agriculture is illegal according to Decree 87-143 of 1987.
Even in countries where only a subsection of agro-conversion may have been audited, there are similarlyhigh levels of illegality. For example, the Supreme Audit Agency of Indonesia found less than 20 percent of
the oil palm sector in compliance with the national laws and regulations – more than 80 percent noncompliance. Overall, where data is available, illegality was reportedly widespread, but limited data availability
or low-quality data constrained analyses and reduced the ability to document illegality.9
Problems with limited data are compounded by contradictions within legal frameworks and make the identificationof legal versus illegal agro-conversion challenging, a situation that not only constrains enforcement efforts but
also investment by actors trying to be responsible. In Indonesia, for example, while the Constitution guarantees
customary rights, national laws and regulations often are inconsistent or undermine these rights. In Bolivia andHonduras forest regulations lack clarity, with laws that simultaneously promote agricultural expansion and theprotection of forests (Bolivia), or declare deforestation for agriculture illegal but agroforestry allowed (Honduras)(Vallejo 2011; Government of Honduras 2008). In many countries around the world, disputes are caused byoverlapping titles and claims, with concessions for logging, mining, and agriculture overlapping each other andlocal land rights – making it difficult to understand the exact drivers of deforestation and enforce non-compliancewith environmental laws and regulations. Malaysia and Vietnam also have contradictory laws defining what islegal versus illegal, and land classifications with mapped boundaries are not publicly available.
Perhaps it should not be surprising that national-level assessments of legal compliance are lacking for somany countries, nor that illegality is widespread. Perpetrators will go to great lengths to hide their illegal
activities and/or launder the products of the illicit harvests. In many of the case study countries, governanceis weak, enforcement under-resourced, corruption widespread, and monitoring and reporting on forest loss
virtually non-existent. Indeed, the majority of tropical countries assessed in this report fall in the lower half of
the Forest Trends (2020) comparative forest governance risk indicators.10 Of the 23 country studies, 17 fallin the lower half, and six in the lowest 20 percent (Appendix 2).

Despite limited official reporting by producer countries, these results
are robust.
Sensitivity analyses (Appendix 1) indicate that, despite the lack of reporting on illegality, Forest Trends’ results
are robust overall. Given the evidence available, Forest Trends can report with confidence that at least 69
percent of agro-conversion in the tropics was illegal between 2013 and 2019. If, instead of relying on theForest Trends used sensitivity analyses, discussed below and in Annex 1: Methodology, to determine the impact on findings ofthe lack of producer-country government evaluation and reporting.
10
Corruption has been shown to be highly correlated with the failure of a country’s public sector to enforce laws or regulate
industries effectively. Nearly half of the world’s forests are in nations with what Transparency International calls “rampant” corruption and most of the forest crimes identified by Interpol and UNEP result from the inability of state forest administrations toenforce laws that regulate timber harvesting and trade. Forest Trends, national governance risk index compares national-level
political, governance, business, economic, and corruption indexes to determine their level of consistency in country assessments. These indices draw on a broad range of relevant underlying data from the World Bank, African Development Bank,
Asian Development Bank, Inter-American Development Bank, International Fund for Agricultural Development’s programming
criteria, United Nations and governmental aggregated data, as well as independent surveys and other primary data. The risk
scores can only give an indication of the likely level of illegal deforestation in a country and ultimately speaks to the risk that
corruption and poor governance undermines rule of law in the forest sector (Forest Trends 2020).
9

DETAILED FINDINGS|

MAY 2021

evidence available, it is assumed that all of the un-audited agro-conversion were illegal, the Forest Trends
estimates of illegal tropical agro-conversion would jump to 94 percent, or 59 percent of all tropical forest
loss. If it were assumed that none of the un-audited agro-conversion were illegal, then Forest Trends’ global
estimate of illegal agro-conversion would only drop from 69 to 61 percent. These could be considered theupper and lower bounds of illegal agro-conversion between 2013 and 2019: unlikely less than 61 percent,but maybe as high as 94 percent.

Soy, palm oil, cocoa, and cattle products (beef and leather) drive global
figures of illegal deforestation, but other commodities, such as rubber,coffee, and maize, are also leading causes of illegal deforestation insome regions, with devastating effect.
Identifiable illegal deforestation is pervasive in the expansion of croplands for soy (93 percent of agroconversion across all soy-growing countries in this study), cocoa (93 percent), and cattle products (beef 81
percent; leather 87 percent). The global average proportion of illegality for palm oil (59 percent) is constrainedby low data availability in Malaysia, although 81 percent of clearing for Indonesia – the world’s leading producerof palm oil – is estimated to be illegal. In Peru, it was estimated that more than 50 percent of oil palm wasgrown on illegally deforested lands.
The direct driver of most forest conversion in South and Central America was the expansion of cattle pasture.
Of pasture in areas cleared of forests, 95 percent of all Brazilian and 97 percent of Mexican beef and leather
products were considered at risk of having been produced on illegal agro-converted land. Illegal agroconversion in Argentina and Paraguay for cattle grazing were estimated at 65 percent and 24 percent,respectively.
Illegal deforestation for the production of soy products was also centered in South America. Ninety-five
percent of Brazilian soy linked to deforestation was estimated to have been produced in violation of nationallaws and regulations, as was 100 percent of soy linked to deforestation in Paraguay. Two thirds of Bolivia’s
soy production is exported, and more than half is likely to come from illegally cleared land.
Cocoa, rubber, wood fiber, and coffee production expanded significantly into forest areas in some countries.
In Ghana, for example, forest conversion for cocoa represents one-third of the country’s total tree cover loss.
In Indonesia, over 1.6 Mha of forest since 2001 has been destroyed for wood fiber plantations and nearlyanother 1 Mha for rubber (Goldman et al. 2020). In Vietnam, 18 percent of forest loss in the Central Highlands
in 2020 was for coffee and in Honduras’ Ocotepeque, it is estimated that 56 percent of deforested land wasconverted to coffee (Chatham House 2020; Carbon Fund 2018).
Despite limits in data availability, non-compliance with national laws and regulations still appears significantly
high – most notably for clearance within protected forest areas. Coffee and cocoa production are expanding
into protected areas in Honduras and West Africa. An estimated 40 percent of cocoa from Cote d’Ivoire is
the result of illegal forest clearing, and 13 percent of cocoa in Ghana is displacing forest, of which 45 percent
is likely illegal. In Argentina, maize is the leading driver of deforestation, of which at least 65 percent is incontravention of land zoning laws. At least 17 percent of all rubber and rubberwood in Laos is estimated tohave been produced on deforested lands and roughly half of rubber is grown in concessions where illegalities
are well documented (98 percent of land leases in Laos are not legally compliant). In Cambodia, all rubber
is likely grown on cleared forests and though illegalities are generally very poorly documented, at least 16
percent of Economic Land Concessions are illegal because they exceeded the maximum size limit.

19

20

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

Emissions from illegal ago-conversion account for at least 41 percent of
all emissions from tropical deforestation.
All tropical forest loss has a massive impact on climate change because of the emissions associated with forest
clearing (e.g., loss of vegetation and other carbon sinks, direct emissions from human activity, etc.) Illegal agroconversion alone was likely responsible for at least 2.7 Gt of CO2e per year, totaling 19 Gt of CO2e between
2013 and 2019. On an annual basis, that’s more than India’s emissions from fossil fuels, and if it were a country,
emissions from illegal agro-conversion would be third-largest globally after China and the US.
The largest producer of emissions from illegal agro-conversion during this time was Latin America (13.7 Gt),
mainly due to massive forest loss in Brazil associated with fires over the last few years. For Brazil, thisrepresents an increase of 54 percent from the preceding seven years (2006 to 2012, according to Harris etal. 2021) when Brazil was seriously addressing illegal logging and deforestation for agriculture and was able
to reduce its total emissions more than any other country in the world.
Deforestation for agro-commodity production that is driven by export demand has increased overall since2013. More than 31 percent of agricultural commodities linked to deforestation are exported, raising significant
concerns about their association with illegal deforestation.
The average annual area of agro-converted land linked to exports has increased from 1.7 Mha per year to
2.0 Mha per year since the original 2000 to 2012 time period studied in Forest Trends’ original report (2014).
In 2019, exports of US$55 billion were linked to agro-conversion across ten commodities – mostly thosegrown in Latin America and Asia. This trade represents emissions of at least 1.2 Gt CO2e per year from morethan 14 Mha of forest land cleared between 2013 and 2019, an area twice the size of Ireland.
This report examines 23 case study countries and finds at least one-fifth – and in some cases virtually all – ofagricultural exports were linked to illegal deforestation, depending on the commodity and country of origin.
It is not possible to calculate at a global level precisely what share of illegally produced commodities areultimately exported from their country of origin. Given the evidence presented here and the regional andcountry studies summaries that follow (Annexes 1-3), the risk of deforestation-linked products is non-negligible,
even high, in the cases of widely traded commodities like soy and palm oil.

The percentage of deforestation for agro-commodity production that isdriven by export demand varies, which will affect the potential impact ofconsumer and demand-side measures.
The overall proportion of production linked to agro-conversion that is then exported has declined from 49
percent in the 2000 to 2012 period to 31 percent since 2013. This is because in some countries, deforestation
is not driven by commercial agriculture (DRC, Madagascar, Sierra Leone) or their agricultural products are
not destined for export (Colombia, Bolivia, Mexico). In these countries especially, demand-side measures
such as corporate purchasing policies or import regulations will be less effective than programs whichstrengthen domestic governance; programs for sustainable management of the land and forest sectors musttake leading roles.
Demand-side measures, however, will be effective when a high proportion of deforestation for agro-commodity
production is being driven by export demand, as is the case, for example, in Indonesia, Malaysia, and Laos.
However, agro-exports are increasingly headed to markets in China and India, where regulatory and consumer
pressure for environmental protections is lower. If demand-side regulatory measures are only adopted inDETAILED FINDINGS|

MAY 2021

some major markets (such as the US, Europe, and Australia) but not in others, a bifurcation of trade is likely,
with high-risk commodities continuing to find buyers in import markets without legislation or trade measures
blocking illicit goods.

Can demand-side initiatives in Europe and North America help reach atipping point?
Over the past decade, mainly in Europe and North America, a variety of demand-side measures have been
designed and, to some degree, implemented by consumers, industry, and consumer governments, such as
corporate purchasing policies, public procurement policies, and import regulations aimed at either eliminating
all deforestation or illegal deforestation from supply chains. Governments in the UK, EU, and the US are
notable for already starting on regulatory approaches to ensure imported agricultural commodities are notbeing sourced from deforested lands, or at least lands that were not illegally deforested. These efforts havebeen supported by certification or legality verification systems, voluntary or regulated disclosure processes,
investor activism, and NGO campaigns.
But the European and North American markets alone may not be enough to affect significant change. For
cocoa products, these markets typically account for over 60% of all global imports and could thus holdsignificant leverage over the entire market (Figure 5), especially for some producer countries such as Nigeria,
Cote d’Ivoire and Cameroon (Figure 6) (Norman & Saunders 2020). However, countries such as Brazil andIndonesia export less than 40% to these markets, and thus demand-side measures are likely to be lesseffective. Producer countries could increasingly export to countries with less market demand for sustainable
and/or legal products. This is already the case for most soy and beef produced in tropical countries, where
China and other countries hold increasingly larger shares of the market (Figures 7 and 8).

Figure 5 | UK, US, and EU share of global cocoa bean, cocoa products, and chocolate imports (%), 2010-2018
2018
2017
2016
2015
2014
2013
2012
2011
2010
0%
United Kingdom

20%

40%

United States of America

Source: Norman and Saunders 2020.

60%
EU27 (2020) + EFTA

80%

100%

All other markets

21

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

22

Figure 6 | Market share of EU, US, and UK imports of cocoa beans, cocoa products, and chocolate, 2019 (% ofglobal imports in kg)
Peru
EcuadorBrazilCameroon
Nigeria
Indonesia
Ghana
Côte d'Ivoire
0%

20%

EU27 (2020) + EFTA

40%

United Kingdom

60%

80%

United States of America

100%

All other markets

Source: Norman and Saunders 2020.

Figure 7 | Global importers of soy from tropical countries, 2015-2019

Trade value (US$ billions)

40

30

20

10

0

2015
China
Russia

2016

2018

2017

Republic of Korea
ThailandEU + EFTA
Colombia
Pakistan
Other Asia
Peru

Indonesia
TurkeyIndia
Ecuador

Source: Data from UN Comtrade, 2018, compiled and analyzed by Forest Trends.

2019
Japan
Vietnam
Other markets

DETAILED FINDINGS|

MAY 2021

Figure 8 | Top global importers of tropical beef (2015-2018)

Trade value (US$ billions)

10
8
6
4
2
0

2015

2016

2017

Hong Kong
United Arab Emirates
China
Egypt
USA
Indonesia
RussiaSaudi Arabia
Philippines
Vietnam

2018

2019

EU+EFTA
Chile
IsraelJordan

Malaysia
Other markets

Source: Data from UN Comtrade, 2018, compiled and analyzed by Forest Trends.

23

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

24

4

Latin America and the
Caribbean Regional Summary

KEY STATISTICS
Forest loss in tropical Latin America and the Caribbean11 (LAC), 2013-2019:13.7 GtCOofe

all forest loss
the tropics
44% ofacrosstotal loss of
33.9 Mhatropical forests

2of which

Total gross emissions
from tree cover loss

to commercial
77% due
agriculture

88% likely illegal
24% likely exportedof which
at least

Figure 9 | Amount of tropical forest loss (Mha) driven by commercial agriculture, by domestic consumption
versus export of commodities and minimum proportion of clearing that was likely illegal; Latin
America and Caribbean data featured
At least

41%

At least

At least

66%

88%

IllegalIllegalIllegalAsia
AfricaLatin America
6.2 Mha19.8 Mha

ExportDomestic

26 Mha33.9

Mha
Total loss tocommercial agriculture 2013-2019 Total forest loss
Minimum extent of illegal agro-conversion:

75-100%50-74%

25-49%

0-24%

Notes: Amount of tropical forest loss driven by commercial agriculture is represented by dark grey circles. The green pie charts
represent the minimum proportion of clearing that was likely illegal, with domestic consumption depicted in light green and production
destined for export in dark green.

Forest/Forest cover: Forest areas with greater than 50
percent tree cover that are greater than five meters tall.
Forest loss/Deforestation: Complete removal of forest cover(areas with at least 51 percent of tree cover).

11

Illegal deforestation: Conversion of forests that takes placein contravention of a country’s legislative framework (e.g.,their laws and regulations) at the time the deforestation took
place. Breaches of international or customary law were notincluded unless they are integrated into national legislation.

47 countries in tropical Latin America and the Caribbean, forest loss according to GFW (2020, using Hansen et al. 2013).

LATIN AMERICA AND THE CARIBBEAN REGIONAL SUMMARY|

MAY 2021

Introduction
BOX 2
Latin America and the Caribbean: Key Findings■ Between 2013 and 2019, commercial agriculture in LAC was likely responsible for the clearance ofmore than 26 Mha of forest (Figure 9).
☐ At least 88% of agro-conversion was likely illegal.
☐ Given that 24% of the production linked to this agro-converion was exported, there is a risk thatinternational buyers are linked to the loss of 6.2 Mha of forest.
☐ These exports carried a high risk of being linked to illegal deforestation.

Figure 10 | Relative amount of tropical forest loss driven by commercial agriculture across case study
countries in Latin America and the Caribbean and the minimum extent of clearing that was illegal

Colombia

BrazilBolivia

Mexico131

Honduras

2
Peru

3
2

1
2

Paraguay
Argentina
Total forest loss
Total forest loss
Total loss due to agro-conversion
Domestic consumption
Exported agro-conversion

Minimum extent of illegal agro-conversion:
75-100% 50-74% 25-49% 0-24%
Availability of data on legality:
1 = high 2 = medium 3 = low

Sources: Forest loss data from GFW (2020, using Hansen et al. [2013]); agro-conversion estimates compiled by Forest Trends (2021)
from multiple sources, including GFW (2020, using Curtis et al. [2018]); export/domestic consumption estimates compiled by Forest
Trends (2021) from multiple sources, including Pendrill et al (2020) and UNComtrade; illegality data estimates compiled by Forest
Trends (2021).

25

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

26

Figure 11 | Distribution of forest loss across tropical Latin America and the Caribbean

Remainder of
Latin America
3.4 Mha

Bolivia
2.5 MhaBrazil20.4 Mha

ColombiaPeru

1.8 MhaParaguay

1.5 MhaMexico
1.6 Mha

1.1 MhaArgentina

Honduras

1 Mha

0.6 MhaSource: GFW (2020, using Hansen et al. 2013).

Latin America lost 34 Mha of forest between 2013 and 2019 (GFW 2020, using Hansen et al. 2013; Figure 8).
This is a 31 percent increase on the forest loss that occurred in the preceding seven year period (e.g., 26
Mha, based on GFW 2020).

Figure 12 | Annual forest loss in Latin America and the Caribbean, 2001 to 2019. This report covers the period
highlighted (2013-2019)8
7
Hectares (millions)

6
5
4
3
2
1
0

‘01

‘02

‘03

‘04

‘05

‘06

‘07

‘08

‘09

‘10

Non-primary forest loss

‘11

‘12

‘13

‘14

‘15

‘16

‘17

‘18

‘19

Primary forest loss

Sources: Forest loss data from GFW (2020, using Hansen et al. [2013]), compiled by Forest Trends.

Commercial agriculture was the dominant driver of forest loss across LAC, mainly for beef and soy (at least
26 Mha between 2013 and 2019, see country studies in Annex 1). Forest Trends estimates that at least 23

LATIN AMERICA AND THE CARIBBEAN REGIONAL SUMMARY|

MAY 2021

Mha, or 88 percent of these forests were cleared in violation of the producer country’s own laws andregulations (Figure 10). The forest loss from commercial agriculture in LAC is estimated to have generated
at least 15 Gt of CO2e during this reference period (GFW 2020, using Harris et al. 2021). Most production on
the land cleared of forests was destined for domestic markets, but 6 Mha of this cleared land (24 percent)
was likely for the production of agro-commodities for export markets, generating 3.5 Gt CO2e of emissions.
While trends vary among the LAC countries, the overall pattern is driven by Brazil which alone constitutes
almost two-thirds (60 percent) of all tropical forest loss across LAC during the study period.

BRAZIL
Brazil, with nearly 500 Mha of forest, dominates the tropical forests of Latin America. Under the National
Plan to Combat Deforestation, and policies and initiatives like the 2006 moratorium on soy producers clearing
forest in the Amazon, and a similar cattle moratorium in 2009, Brazil successfully reduced its rate of
deforestation. Unfortunately, this success has been reversed, and the Government of Brazil reports that theannual rate of primary forest loss in 2020 was 26 percent greater than 2012 (PRODES 2020). Brazil lost over
20 Mha of forest cover between 2013 and 2019, more than one-quarter of all forest loss across all the tropics.
The main driver was commercial agriculture, responsible for 88 percent of Brazil’s forest loss.
Like the rest of Latin America, the major agricultural commodities responsible for deforestation in Brazil are
beef and soy. Pasture drove 74 percent and soy drove 20 percent of forest loss in Brazil, but the dynamics
are complex: soy often displaces pastures, moving livestock expansion further into the Amazon (MapBiomas2020). While Brazil dominates, these patterns of direct and indirect loss were common across Latin America.
Trase (2020a) estimates that pasture for livestock was responsible for 81 percent of deforestation in theBrazilian Amazon, and over 95 percent of the deforestation in the Paraguayan Chaco.
Across the region, forest clearance for commercial agriculture is occurring in violation of national laws andregulations (Figure 10). Almost all agro-conversion in Brazil is illegal, evidenced primarily by a lack of proper
permits allowing forest clearing, but also by fraudulent land titles and non-compliance with the Forest Coderequirements. Brazil’s data on illegality in agro-conversion has been well documented through independent
analyses of commercial agriculture’s lack of compliance with national legislative frameworks relevant to forest
clearing (Rezende de Azevedo et al. 2019; Rajão et al. 2020; Trase 2020b).
Across the rest of Latin America, such systematic analyses are rare, but a review of the literature suggests that,like Brazil, illegality is likely high across all countries, with estimates ranging from 97 percent in Mexico and 89
percent in Colombia, down to at least 50 percent in Peru and 49 percent in Paraguay. However, as theseestimates are based only on limited, albeit well documented, evidence of illegalities, it is likely that morecomprehensive reviews would indicate even greater levels of illegality, making these estimates conservative.12
Recently the region has seen a worrying weakening of national laws, policies, and institutions that protect forests.
Brazil has been worst affected, with laws that gave impunity for deforestation in legal reserves and areas ofpermanent preservation, and amnesty for land seizures. Since Bolsonaro came to power, the dismantling ofenvironmental protections has accelerated, including the elimination of key environmental positions, the militarizationof environmental investigations, and the marginalization of civil society (Rajão et al. 2020; Carrero et al. 2020).

12

For example, Forest Trends knows of no review of tax evasion associated with forest clearing but knows that tax evasion is
a common problem in the region. It is possible that in Latin America, like in Indonesia (where a comprehensive review wasundertaken), operators have failed to pay taxes on conversion timber harvested during land clearing.

27

28

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

Soy and beef linked to deforested land in the six Latin American case studies (Annex 1) have a combined
value of US$24 billion in 2019. Given that Brazil has the highest amount of agro-conversion, and almost all
this clearing is likely illegal, Brazil also comprises the highest proportion of all forest risk commodities exported,
valued at over US$19 billion for 2019. The biggest producers are responsible for almost all of Brazil’s forest
loss: 2 percent of producers are responsible for 62 percent of all deforestation (Rajão et al. 2020), almost
all of it likely illegal. More recently, Brazil’s agro-exports are increasingly heading to China, which has
strengthened Brazilian producers’ demands to end the zero deforestation requirements for soy in the Amazon.
The gains originally made before 2016 in reducing deforestation meant that Brazil may have done more thanany other country to address the climate crisis – at its peak, Brazil likely reduced emissions by more than 1.3
Gt of CO2e per year. By comparison, in their best year, the US, Japan, and the EU together only reduced
emissions by less than a quarter of what Brazil accomplished. Unfortunately, these gains are now being lost,and emissions from deforestation are on the rise again.

THE ANDEAN-AMAZONIAN STATESIn Bolivia, at least 80 percent of forest loss is driven by commercial agriculture (GFW 2020; FAO FRA 2020;
Müller 2013), while in Peru, there is a mixed picture of large-scale and smallholder agriculture, with coffee,cocoa, and palm oil responsible for most agro-conversion (Zegarra Méndez & Gayoso 2015; Augusto 2020;
Government of Peru 2016). In Colombia, land grabbing under the guise of cattle ranching is the primary driver(responsible for 60 to 65 percent of deforestation according to the Ministry of the Environment), with illegal
coca farming accounting for a further 20 to 22 percent (Minambiente 2017). High levels of illegality reflect
weak rule of law, corruption, failure to implement Free Prior and Informed Consent (FPIC), and intimidationof environmental defenders. The likely trend is for commercial agriculture to increase as a driver of deforestationin these countries, given national strategies to promote livestock (Bolivia) or palm oil (Peru), incentives forfarmers to grow cash crops such as cocoa and coffee, rocketing land prices, and the growth of illicit cocacultivation (Colombia).
Forest loss in Bolivia spiked in 2019, 80 percent higher than the next highest year on record, due to fires
that devastated huge areas, especially the Chiquitano dry forest in the province of Santa Cruz, a hub ofcommercial agriculture. The Chaco forest also experienced large-scale conversion to pasture. The legal
framework protecting the forests was eroded by laws that favored agri-business, waiving fines for illegal
deforestation and allowing controlled burns in lowland forests. The Law of the Rights of Mother Earth, which
boosted Bolivia’s environmental credentials in 2010, was not followed up with implementing environmental
legislation nor the repeal of contradictory laws, and appears now to have been little more than windowdressing (Romero-Muñoz et al. 2019; Villavicencio Calzadilla & Kotzé 2018). A World Resources Institute (2016)
report found that deforestation rates were 2.8 times lower within “tenure-secure” indigenous lands — lands
that are legally recognized by the government and protected from external threats and competing claims— than outside of them. By giving indigenous groups legal rights to the lands they occupy, Bolivia could
avoid 8 to 12 Mt of greenhouse gas emissions each year.
Brazil was not alone in reporting a rising rate of forest loss due to commercial agriculture; deforestation in
Colombia has increased in areas previously isolated by the civil war, and the Gran Chaco dry forests haveexperienced intensive conversion, in part as a leakage effect of zero deforestation commitments in theBrazilian Amazon.

LATIN AMERICA AND THE CARIBBEAN REGIONAL SUMMARY|

MAY 2021

Colombia’s transition to peace led to an increase in deforestation in former FARC-controlled areas13 where
forest cover had previously given a strategic advantage to the rebel groups. Now criminal gangs work
together with FARC splinter groups to seize land and/or extract extortion money from farmers for each hectare
deforested. Land grabbing has driven 60 to 65 percent of deforestation. Most of Colombia’s deforestation
is located in the Amazon region (68 percent in 2020), and the majority is converted to pasture (IDEAM 2020;
González et al. 2018), with livestock moved onto cleared land as a way of signaling ownership. The expansionof pasture is not export-oriented, however, as almost all beef is consumed on the domestic market. The root
cause of much deforestation is land speculation, with the price of land rocketing as much as 300 percent insome areas (Volckhausen 2019).
Smallholders in the Peruvian Amazon grow both subsistence and cash crops, and census data shows nearly
half a million farmers living in the Amazon. It is estimated that roughly 68 percent of farming in the Amazon
is illegal, with farmers illegally occupying public lands (Gonzalo 2020).

THE SOUTHERN CONE
Paraguay and Argentina each lost over 1 Mha of forest between 2013 and 2019, and commercial agriculture
was responsible for 89 percent and 71 percent, respectively. The semi-arid lowlands of the Gran Chaco whichcontain South America’s second largest forest, stretching across Argentina, Bolivia, Paraguay, and Brazil,
have been the site of aggressive agricultural expansion. The forest is first cleared for cattle ranching thensold or rented out for more lucrative soy production. Thus, soy is the indirect driver of land-use change,
pushing cattle ranching further into frontier areas and driving up local land prices, which in turn, incentivizes
the clearing of surrounding forest. In Argentina, there is a legal requirement to zone land based on its
conservation value, but by 2018, this process had been completed for only 19 percent of the country’s landarea. An analysis of deforestation in 2017 found that 65 percent took place in zones where deforestation
was prohibited or on land that was not zoned (Greenpeace Argentina 2018; Gutman 2018).
Paraguay and Argentina are among the top five global exporters of soybeans. Paraguay sold 6.8 Mt in 2019and soy accounts for 50 percent of its exports. Nearly all of Paraguay’s soy exports come from the east of
the country, the heavily deforested Atlantic Forest, which experienced most of its forest loss before the Zero
Deforestation Law of 2004. The law applies only to the Atlantic Forest and led to a sharp increase in conversion
in the Gran Chaco instead. For decades, Paraguay has had huge land inequality, with just 1.6 percent of the
population owning 80 percent of all agricultural land. While landlessness and poverty are forced upon people
evicted from their land, the landowning elite export beef and soy overseas. Beef accounted for 25 percent
of Paraguay’s export revenue in 2019, mostly destined for Chile and Russia, and none of the export has azero deforestation commitment. Leather from deforested land, home to the Totobiegosode Indigenous
Peoples, is reportedly exported to Italy for use in luxury cars, such as BMWs and Range Rovers (Earthsight2020). The Gran Chaco is the ancestral territory of many indigenous peoples, most notably the Ayoreo,
whose territory extends over 11 Mha. Despite Paraguay’s constitutional recognition of the right to communal
land ownership, the Inter-American Court of Human Rights has made three judgments criticizing violationsof the land rights of indigenous peoples and the deforestation of customary lands. Paraguay’s remaining
forests are at high risk of further rapid deforestation given the weakening of forest protections introduced
in 2017.

13

Fuerzas Armadas Revolucionarias de Colombia or “The Revolutionary Armed Forces of Colombia.” Most commonly known as
FARC, the acronym in Spanish.

29

30

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

CENTRAL AMERICAIn Mexico, commercial agriculture is the driver of 68 percent of forest loss, with a mix of large livestock farms
and smaller rainfed or irrigated fields for crops and fruit. Agro-conversion is illegal where authorization has
not been obtained for land-use change from the Ministry of the Environment and Natural Resources. Between
2005 and 2015, only 37,713 ha of land-use change from forestry to agriculture were authorized, equivalent
to 3 percent of forest loss during this period, implying that 97 percent of agro-conversion is likely illegal.
Nearly half (45 percent) of Mexico’s exported deforestation risk is in beef (Pendrill et al. 2020). The numberof cattle in Mexico nearly doubled over the period 2013 to 2018 and in deforestation hotspots such as Chiapas,
cattle ranching is identified as the main driver of forest loss (Soberanes 2018). Beef exports from Mexico
were valued at over US$1 billion in 2018, mostly going to the United States. Deforestation for avocados isanother risk, located mostly in central and southern Mexico. For example, the avocado orchards of Michoacánstate caused at least a further 10 percent of Mexico’s annual forest loss and the destruction of much of theremaining habitat of the endangered monarch butterfly (GFW 2019).
Like Mexico, deforestation in Honduras is driven almost entirely by commercial agriculture. One of thegrowing causes of deforestation is coffee – in fact, Honduras is responsible for 32 percent of the world’s
embodied deforestation in coffee (Pendrill et al. 2020). Roughly 29 percent of the area under coffee cultivationis on land that was illegally converted from forest to agriculture (Carbon Fund 2018).

CONCLUSION
The countries selected for this analysis have the largest forest loss, but deforestation is a problem across
LAC. An additional 3.3 Mha (11 percent of all loss across Latin America) was lost in the other 40 countries
across the continent (Figure 11), where agriculture is also the main driver: mostly shifting agriculture in Nicaraguaand Guatemala, while in Venezuela the conversion of forest lands was for the production of beef sold on
the domestic market. The effects are extensive habitat loss, release of emissions, soil depletion, water scarcity,labor abuses, and landlessness.
In LAC, there is a high risk that commodities are grown on illegally deforested land. Brazil has set the standard
by having a database of private property boundaries that makes it possible to use satellite observations todetermine compliance with the Forest Code. In all other countries, determining illegality is complex, if not
impossible. Forest Trends estimates are based on evidence from the documented illegalities contained in
the country studies herein (Annex 1). Further research will undoubtedly reveal higher levels of illegality.
Indigenous peoples and local communities across Latin America have legal rights to manage more than 270
Mha of forest, almost 40 percent of the total forest area (and also claim significant areas that they do not yet
have formal rights to), and yet they are often forced off their land by ranchers, land grabbers, and criminal
gangs (Graesser 2015). Even in countries such as Bolivia and Colombia, where their constitutions enshrine
customary rights, these rights are routinely ignored.
Insecure land tenure, land grabbing, and land speculation are at the heart of illegal deforestation in Latin
America. Threats and intimidation often accompany land clearance, and the arrival of cattle is a precursor to
fencing off pastures and claiming land titles. Illicit crops, such as coca, are also a major factor, especially inCentral America, Colombia, Bolivia, and Peru.
There is a risk that environmental laws will continue to be weakened in the face of pressure from agribusinessand large landowners, as has been the case in Brazil (the Forest Code of 2012 and Law 13,465 of 2017) andLATIN AMERICA AND THE CARIBBEAN REGIONAL SUMMARY|

MAY 2021

Bolivia (Supreme Decree 3973 and Law 1098). Furthermore, the COVID-19 pandemic has been used as anopportunity to weaken forest protections. In Peru, environmental monitoring was put on hold and reports ofland invasions went uninvestigated while extractive industries were promoted. In Colombia, community
consultation guidelines were weakened and between March and May 2020 in Brazil, 195 Executive Acts
bypassing or dismantling environmental regulations were signed (Dil et al. 2021). As demonstrated by thechallenges to preventing forest loss in Latin America, forest protection requires strong standards of environmental
and social protection, and companies need enhanced environmental and human rights due diligence.

31

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

32

5Africa Regional Summary

KEY STATISTICS
Tropical forest loss in Africa, 2013-2019:11.5 GtCOofe

all forest loss
the tropics
25% ofacross19.3

Mha total loss oftropical forests

2

Total gross emissions
from tree cover loss

10

due to commercial% agricultureof which

66% likely illegal
4% likely exportedof which
at least

Figure 13 | Amount of tropical forest loss (Mha) driven by commercial agriculture, by domestic consumption versus
export of commodities and minimum proportion of clearing that was likely illegal, Africa highlighted
At least

41%

At least

At least

66%

88%

IllegalIllegalIllegalAsia
AfricaLatin America

0.5 Mha

1.5 MhaExportDomestic

2.0 MhaTotal loss tocommercial agriculture

19.3 Mha

Total forest loss

2013-2019
Minimum extent of illegal agro-conversion:

75-100%50-74%

25-49%

0-24%

Notes: Amount of tropical forest loss driven by commercial agriculture is represented by dark grey circles. The green pie charts
represent the minimum proportion of clearing that was likely illegal, with domestic consumption depicted in light green and production
destined for export in dark green.

Forest/Forest cover: Forest areas with greater than 50
percent tree cover that are greater than five meters tall.
Forest loss/Deforestation: Complete removal of forest cover(areas with at least 51 percent of tree cover).

Illegal deforestation: Conversion of forests that takes placein contravention of a country’s legislative framework (e.g.,their laws and regulations) at the time the deforestation took
place. Breaches of international or customary law were notincluded unless they are integrated into national legislation.

AFRICA REGIONAL SUMMARY|33

MAY 2021

Introduction
BOX 3
Africa: Key Findings■ Between 2013 and 2019, commercial agriculture in Africa was likely responsible for the clearance ofmore than 2 Mha of forest (Figure 13).
☐ At least 66% of agro-conversion was likely illegal.
☐ Given that 26% of the production linked to this agro-conversion was exported, there is a risk thatinternational buyers are linked to the loss of 0.5 Mha of forest and are at high risk of being linked
to illegal deforestation.

Figure 14 | Relative amount of tropical forest loss driven by commercial agriculture across the case study
countries in Africa and the minimum extent of clearing that was illegal

Democratic Republic
Sierra Leoneof Congo
Ghana
Madagascar
Côte
d’Ivoire
Liberia

32 2
2

1
1
3

AngolaTotal forest loss

Total forest loss
Total loss due to agro-conversion
Domestic consumption
Exported agro-conversion

Minimum extent of illegal agro-conversion:
75-100% 50-74% 25-49% 0-24%
Availability of data on legality:
1 = high 2 = medium 3 = low

Sources: Forest loss data from GFW (2020, using Hansen et al. [2013]); agro-conversion estimates compiled by Forest Trends (2021)
from multiple sources, including GFW (2020, using Curtis et al. [2018]); export/domestic consumption estimates compiled by Forest
Trends (2021) from multiple sources, including Pendrill et al (2020) and UNComtrade; illegality data estimates compiled by Forest
Trends (2021).

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

34

Figure 15 | Distribution of forest loss across tropical Africa

Madagascar
2 Mha

Liberia
1.2 Mha

Democratic Republicof Congo
8.1 MhaSierra Leone

Remainder ofAfrica
4.7 MhaCôted’Ivoire

1 Mha

0.9 MhaAngolaGhana

0.9 Mha

0.4 MhaSource: GFW (2020, using Hansen et al. 2013).

Figure 16 | Annual forest loss in Africa, 2001 to 2019. This report covers the period highlighted (2013-2019)
4.0
3.5
Hectares (millions)

3.0
2.5
2.0
1.5
1.0
0.5
0

‘01

‘02

‘03

‘04

‘05

‘06

‘07

‘08

‘09

‘10

Non-primary forest loss

‘11

‘12

‘13

‘14

‘15

‘16

‘17

‘18

‘19

Primary forest loss

Source: Forest loss data from GFW (2020, using Hansen et al. [2013]), compiled by Forest Trends.

Unlike other major tropical regions, commercial agriculture in Africa is not the dominant driver of forest loss
(Figure 3, Detailed Findings). The exception is certain parts of West Africa, where the cultivation of export-oriented
cocoa encroaches increasingly into protected areas, and where the remaining closed canopy forest fragments
are increasingly isolated within a mostly degraded landscape. In East Africa, the deforestation of the dry forests
is characterized by small-scale clearance conducted by extended families who cut the trees in labor intensive
ways, mainly to produce fuel, food crops for sale in the local market, and for personal consumption (Rudel 2017).
By far the largest losses of forests across the continent are in Central Africa, mostly in the Congo River Basin,

AFRICA REGIONAL SUMMARY|

MAY 2021

which alone comprised 56 percent of tropical Africa’s forest loss between 2013 and 2019 (Figure 15; Figure 16;
GFW 2020, using Hansen et al. 2013). However, the tropical forests of the Congo Basin are mainly threatenedby logging concessions that reportedly cover more than 50 Mha and cut a network of roads into the forest,
opening it up to smaller-scale farming, mining, and further artisanal logging.
Across Africa, national laws for the protection of forests and forest peoples are weak and the application of
the law is often weaker. Logging and agricultural concessions in several countries are accused of violationsof national laws and regulations (Figure 14, right), including expansion into protected areas, taking the land
without informed consent, extending the concession beyond the agreed boundaries, breaching environmental
regulations, failing to pay taxes and other fees, failing to compensate those affected by the clearing, andhuman rights abuses.

THE CONGO BASIN
The equatorial forest of the Congo Basin is the world’s second largest area of contiguous tropical rainforest.
The Congo River watershed spans 3.7 million square kilometers (km2), most of which remains forested. The
forest is home to more than 600 tree species and 10,000 animal species. The presence of elephants, gorillas,
and large herbivores shapes the distinctive forest structure, as their grazing allows the trees to grow taller
and at a lower density than in the forests of Southeast Asia and the Amazon (Butler 2020). It is also hometo the world’s most extensive peatland complex, covering 14.5 Mha. The deep peat layers have been building
up for nearly 11,000 years beneath waterlogged swamp forest and now harbor 30 Gt of carbon – nearly athird of the world’s tropical peatland carbon (Dargie et al. 2017).
The Democratic Republic of Congo (DRC), home to 59 percent of the Congo Basin’s rainforest, lost 5
percent of its forest, or 8.1 Mha, between 2013 and 2019, accounting for 11 percent of all forest loss acrossthe entire tropics over that time (Figure 15). GFW (2020, using Curtis et al. 2018) identifies subsistence
agriculture as the main driver of deforestation (99 percent), but the story is more complex. Logging is taking
place on an industrial scale, and logging roads are opening the forest for conversion to agriculture. At least
10.7 Mha of logging concessions cover 7 percent of DRC’s forests (Global Witness 2018b; Egunda Ikala et al.
2018) and Chatham House estimates 99 percent of timber production is illegal (Hoare 2015). In many cases,
migrants move in when logging opens up the forest, often seeking to escape hunger or conflict (Turubanova
et al. 2018; Lescuyer 2014).
The major crops cultivated in cleared forest areas are cassava, rice, maize, and plantain, all staple foods thatare grown for subsistence but also for domestic markets (Pendrill et al. 2020). Distinguishing between
subsistence and commercial agriculture is complicated, especially when many of the openings created bydeforestation events are small and little data exists on where the crops are destined to be consumed. Demand
from domestic markets is growing and influencing small farmers’ decision-making as to which commodity
crops to plant (Ordway et al. 2017).
Large-scale commercial land uses reportedly cause a small proportion of the deforestation, but where it
occurs, it has both direct and indirect effects. A study by Molinario et al. (2020) found an increased likelihoodof forest loss within a five-kilometer radius of commercial agriculture. The government’s plan to grant large
concessions under the National Agricultural Investment Plan for 2013 to 2020 ran aground when the firstagro-industrial park at Bukanga Lonzo, Bandundu province was closed after a few short years following
allegations of fraud and corruption (Mousseau 2019).
The pattern is similar across the rest of the Congo Basin. In the Republic of Congo and Gabon, large-scale

35

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

commercial agriculture and associated exports are rare, due to high transaction costs and a perceived highrisk investment climate (Austin et al. 2017). However, extensive logging operations – many illegal – create a
network of roads, which makes the area accessible to small-scale farmers, further degrading the forest so it
becomes dry and prone to fire. The few plantations that do exist are reportedly beset by human rights abuses.
Cameroon’s Société Sud Hevea Cameroun is one such example: it is part owned by the president’s family
and was reportedly established without FPIC from local communities. Management also allegedly used force
to remove the local communities, including indigenous Baka people, from the land (Greenpeace Africa 2018;
Rainforest Foundation 2016).
Across the Congo Basin, conflicts over the land and use rights of the forest areas have been relatively well
documented, as have instances of illegal deforestation associated with corruption and forced displacementof local communities.

WEST AFRICA
Deforestation in West Africa is dominated by smallholder farmers encroaching into the last remaining areasof forest, primarily to cultivate cocoa, although large-scale, export-driven oil palm plantations are increasingly
important drivers in Liberia. Migration of poor and often landless rural families into degraded forest, thinnedby years of over-intensive logging, often leads to the conversion of forests to agriculture. Deforestation is
intrinsically linked to non-compliance with national laws and regulations, where concessions are accused of
non-payment of taxes, extending concessions beyond permitted boundaries, and a failure to compensate
affected parties as required. Human rights abuses and child labor remain a particular problem. The countries
that do not have FPIC enshrined in law have been reported to have the most extensive instances of landacquisition by force and intimidation.
Côte d’Ivoire has lost approximately 90 percent of its forests since its independence in 1960, and it lost
almost 1 Mha between 2013 and 2019, which accounts for 5 percent of forest loss across tropical Africa duringthat time. Deforestation in Ghana has been so extensive that the country could soon lose all of its forests
outside of protected areas; almost 0.5 Mha was lost, accounting for 2 percent of all forest lost in Africa
between 2013 and 2019. The governments of Côte d’Ivoire and Ghana identify agriculture as the main driverof deforestation, citing traditional cash crops such as cocoa, cashews, rubber, coffee, palm oil, fruit, andcotton, most of which are grown for export (REDD+ 2017). Indeed, Côte d’Ivoire and Ghana are the world’s
leading cocoa (Theobromo cacao Mavlaceae) growers, together contributing 60 percent of world production.
In Côte d’Ivoire, up to 40 percent of the nation’s cocoa was illegally sourced from inside national parks andprotected areas (Higonnet et al. 2018), with one study concluding that 74 percent of protected areas in Coted’Ivoire had been converted to cocoa (Bitty et al. 2015). Sierra Leone lost 1 Mha of forests between 2013
and 2019, contributing 5 percent of Africa’s total tropical forests loss. Cocoa and coffee are the country’s
main agricultural exports, but cocoa reportedly embodies only 1 percent of deforestation (Pendrill et al. 2020).
Sierra Leone’s increase in deforestation is reportedly due to slash and burn agriculture, firewood and charcoal
production, mining, and timber production. Cocoa is also significant in Nigeria, where it is the third largest
export. The Omo Forest Reserve, in Nigeria’s southwest state of Ogun, lost 7 percent of its tree cover between
2001 and 2018 due to illegal cocoa farming (Sunday 2019).
Liberia is the one outlier – at least 14 percent of its deforestation is driven by commercial agriculture
concessions, rather than subsistence agriculture, indicating a level of foreign investment in agriculturalcommodities that is unusual in the rest of West Africa. Liberia lost 1.2 Mha of forest between 2013 and 19,

AFRICA REGIONAL SUMMARY

Voluntary Commitments for Zero
Deforestation and Child Labor
In 2017, major companies committed to zero deforestationcocoa under the Cocoa & Forests Initiative (Higonnet et al.
2018), while others also made commitments of a 70 percent
reduction in the use of child labor by 2020 (Fountain &Huetz-Adams 2018). Most companies acknowledge thedifficulty they have had making significant progress towards
achieving these commitments. Deforestation for cocoa
continues to be reported as highly associated with humanrights abuses, child labor, and use of hazardous pesticides.
Cocoa expansion combined with low productivity and pricecrashes have increased demand for labor at lower wages.
An estimated 2.1 million children work in cocoa fields in Côte
d’Ivoire and Ghana (Fountain & Huetz-Adams 2018). Cocoa
farmers earn an average of US$0.78 a day, significantly below
the living wage of US$2.51, and typically lack the bargaining
power needed in a sector dominated by multinational
companies (Fountain & Huetz-Adams 2018). However, childlabor and deforestation pose a significant reputational risk
to companies sourcing cocoa from West Africa.

|

MAY 2021

accounting for 6 percent of all of Africa’s
forest loss during this time. Illegalities
in the oil palm concessions include alack of FPIC (as required by law) andthe intimidation of community members,
and it is feared that the concessions
may contribute to renewed conflict ora return to armed fighting a decade after
the civil war ended (Global Witness 2011;
UN Panel of Experts 2013).

EAST AFRICA

East African forests are diverse andinclude transboundary ecosystems,
such as montane forests, miombo
woodlands, coastal forests, andmangroves (Mwangi et al. 2018). The
forests of East Africa contributesignificantly to the local economy andlivelihoods of rural and poor
communities. Most deforestation isdriven by subsistence agriculture,
though growing urban demand forcharcoal and fuelwood is also a factor.
Madagascar has experienced the most deforestation (2 Mha) during this period, losing 17 percent of its 2000
forest cover and contributing to 11 percent of forest loss across all of tropical Africa. In Madagascar, all agroconversion is illegal, but the law is rarely enforced. Like other countries in East Africa, small-scale farming
and fuel wood collection drove most of its deforestation (UN-REDD Programme 2016). Extended periods ofacute drought in the south of the Madagascar have led to increased numbers and a greater permanenceof migrants moving up the west coast, settling, clearing forest for subsistence, and working on new cash
crop projects that take advantage of the influx of labor to clear new areas of forest. The rainforests in eastern
Madagascar are under increasing pressure from agriculture and mining, with protected areas threatened,
and growing lawlessness related to the extraction of natural resources (Whyner 2021).
Deforestation is high in areas with weak management and poor tenure security, such as open access landin Tanzania (0.5 Mha of forest loss between 2013 and 2019) and communal lands in Kenya (less than 10,000
ha of forest loss between 2013 and 2019). In Uganda (less than 40,000 ha of forest loss between 2013 and2019), deforestation is highest in private forests, with less deforestation in government-managed publicforests, especially in protected areas (Mwangi et al. 2018). These fragmented forests are at risk of further
degradation without locally adapted policies that respond to the specific needs of diverse governance andcommunity-level drivers present in the region.

37

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

CONCLUSION
Between 2013 and 2019, Africa was responsible for 25 percent of global tropical deforestation, with Central
Africa responsible for 56 percent of Africa’s forest loss, followed by West Africa (22 percent) and East Africa(20 percent). Most of the deforestation in Africa was reportedly for subsistence agriculture, although a few
outliers exist, such as Liberia, where at least 14 percent of forest loss was driven by oil palm and timber
concessions.
It is likely that the deforestation driven by commercial agriculture and logging is underestimated across Africa.
During the reference period of this report, many countries saw a dramatic jump in the reported levels offorest loss, and there is no obvious reason why subsistence farming would drive such an increase, giventhat population size and diet has not increased at the same pace. Global Forest Watch itself (Curtis et al.
2018) also recognizes that it likely underestimates the role of commercial agriculture because of, for example,
the difficulty in distinguishing among drivers of small patches of forest loss, especially when there is a lag
between clearing and the planting of cash crops. It may be that many farmers grow crops for themselves
and also for some small income. Regardless, it is known that extensive commercial logging causes forest
degradation across Africa and deforestation often follows in its wake. At present, the race for timber is at theheart of deforestation in Africa, with palm oil and cocoa for export driving deforestation in parts of West Africa.
Across the board, agro-conversion is intrinsically linked with illegalities, whether it be by large concessions
or smaller forest clearings for cash crops destined for domestic markets or longer international supply chains.
Government regulations are weak and effective enforcement is hampered by inadequate resources (bothfinancial and human), corruption, and the sheer geographic scale of Africa’s forest areas. In most countries,
FPIC, international law, and customary land rights are not enshrined in national legislative frameworks,
exposing indigenous peoples and local communities to increased risk of dispossession and eviction fromtheir land. Agricultural supply chains face reputational risks of being associated with land grabs and humanrights abuses.
With improved transportation networks and enhanced security, it is likely that commercial agriculture will
increase, and thus the risk of deforestation and associated illegalities will also increase. Nearly three times
as much forest has been lost in the last seven years compared to the first seven years of the century and, if
governments and businesses continue to act with impunity, this trend will continue.

ASIA-PACIFIC REGIONAL SUMMARY6|

MAY 2021

Asia-Pacific Regional Summary

KEY STATISTICS
Forest loss in tropical Asia-Pacific,14 2013-2019:

14.6GtCOofe

all forest loss
the tropics
31% ofacross

23.7

Total gross emissions
from tree cover loss2

Mha total loss oftropical forestsof which76

due to commercial% agriculture

41% likely illegal
42% likely exportedof which
at least

Figure 17 | Amount of tropical forest loss (Mha) driven by commercial agriculture, by domestic consumption versus
export of commodities and minimum proportion of clearing that was likely illegal, Asia-Pacific highlighted
At least

41%

At least

66%

At least

88%

IllegalIllegalIllegalAsia

7.6 MhaExportAfricaLatin America

10.5 Mha

Domestic

18.1 Mha

Total loss tocommercial agriculture

23.7 Mha

Total forest loss

2013-2019
Minimum extent of illegal agro-conversion:

75-100%50-74%

25-49%

0-24%

Notes: Amount of tropical forest loss driven by commercial agriculture is represented by dark grey circles. The green pie charts
represent the minimum proportion of clearing that was likely illegal, with domestic consumption depicted in light green and production
destined for export in dark green.

Forest/Forest cover: Forest areas with greater than 50
percent tree cover that are greater than five meters tall.
Forest loss/Deforestation: Complete removal of forest cover(areas with at least 51 percent of tree cover).

14

Illegal deforestation: Conversion of forests that takes placein contravention of a country’s legislative framework (e.g.,their laws and regulations) at the time the deforestation took
place. Breaches of international or customary law were notincluded unless they are integrated into national legislation.

23 countries in Tropical South Asia, Southeast Asia, and Oceania.

39

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

40

Introduction
BOX 2
Asia-Pacific: Key Findings■ Between 2013 and 2019, commercial agriculture in Asia-Pacific was likely responsible for the clearanceof more than 18 Mha of forest (Figure 17).
☐ At least 41% of agro-conversion was likely illegal.
☐ Given that 42% of the production linked to this agro-converion was exported, there is a risk thatinternational buyers are linked to the loss of 7.6 Mha of forest and carry a high risk of being linked
to illegal deforestation.

Figure 18 | Relative amount of tropical forest loss driven by commercial agriculture across the case study
countries in Asia-Pacific and the minimum extent of clearing that was illegal

MyanmarVietnamLaos
Indonesia
Papua
New
Guinea

3 2
2 2 3
3

Thailand
Malaysia
Cambodia
Total forest loss
Total loss due to agro-conversion
Domestic consumption
Exported agro-conversion

2

2

Total forest loss
Minimum extent of illegal agro-conversion:
75-100% 50-74% 25-49% 0-24%
Availability of data on legality:
1 = high 2 = medium 3 = low

Sources: Forest loss data from GFW (2020, using Hansen et al. [2013]); agro-conversion estimates compiled by Forest Trends (2021)
from multiple sources, including GFW (2020, using Curtis et al. [2018]); export/domestic consumption estimates compiled by Forest
Trends (2021) from multiple sources, including Pendrill et al (2020) and UNComtrade; illegality data estimates compiled by Forest
Trends (2021).

ASIA-PACIFIC REGIONAL SUMMARY|41

MAY 2021

Figure 19 | Distribution of forest loss across tropical Asia-PacificRemainderof Asia
1.8 MhaLaos
Malaysia

2 Mha

3.3 MhaIndonesia
10.6 Mha

Cambodia Thailand

Vietnam

Myanmar

0.9 Mha

0.9 Mha

1.4 Mha

2 Mha

Papua New Guinea
0.8 MhaSource: GFW (2020, using Hansen et al. 2013).

Figure 20 | Annual forest loss in Asia-Pacific, 2001 to 2019. This report covers the period highlighted (2013-2019)
5.0
4.5

Hectares (millions)

4.0
3.5
3.0
2.5
2.0
1.5
1.0
0.5
0

‘01

‘02

‘03

‘04

‘05

‘06

‘07

‘08

‘09

‘10

Non-primary forest loss

‘11

‘12

‘13

‘14

‘15

‘16

‘17

‘18

‘19

Primary forest loss

Source: Forest loss data from GFW (2020, using Hansen et al. [2013]), compiled by Forest Trends.

The Asia-Pacific region was responsible for approximately one-third (31 percent) of all forest loss across thetropics between 2013 and 2019. More than three-quarters (76 percent) was reportedly driven by commercial
agriculture, mainly oil palm and pulp plantations, but also cash crops like coffee and chocolate. Approximately
42 percent of the production linked to the agro-conversion was likely for export, and Forest Trends estimatesthat at least 41 percent of the loss was in violation of local laws and regulations governing forest clearing(Figure 17). The actual amount of illegal deforestation, however, was difficult to determine due to a lack ofsector-wide compliance reviews, and thus a lack of publicly available data on rates of illegality (Figure 18).

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

SOUTHEAST ASIA
Southeast Asia’s rainforests are as rich in biodiversity as any other tropical forest, but they are uniquely
dominated by a family of tree species of high commercial value (Dipterocarpacae). No other tropical forest
is comparable. For example, the island of Borneo alone exported as much timber in the 1980s and 1990s as
all of South America and Africa combined (Curran et al. 2004). This high density of high value trees hascreated incentives for plantation or agricultural concessionaires to clear forests to gain revenue before any
initial investments in planting are made, even when degraded forests were readily available for planting.
This economic incentive has helped drive deforestation, especially of primary forests, across Asia-Pacific.
While the situation in each Southeast Asian country varies, the overall regional trends are driven by Indonesia,
which alone constitutes almost half (45 percent) of all tropical forest loss across Asia during the study period(Figures 19 & 20).
Having lost more than 10.6 Mha of forest, Indonesia was responsible for 14 percent of all forest loss acrossthe tropics, ranking second overall (after Brazil). These losses have been tied to billions of dollars in economic
losses, such as those resulting from the El Niño drought-linked forest fires that created massive haze events.
Despite these large losses, Indonesia has made great progress in reducing the amount of deforestation
since the start of the 21st century, with the Letter of Intent between the governments of Indonesia and Norway,
the creation of the Peat Restoration Agency (Badan Restorasi Gambut or BRG), and a 2016 moratorium on
the clearing of certain peatlands and areas of primary forest – and augmented by declining rubber and palm
oil prices. Because so much of Indonesia’s forests are on peatlands – more than any other country in theworld – reducing its deforestation has had a dramatic impact on its greenhouse gas emissions. In 2019,
Indonesia received almost US$160 million in compensation from the UN Green Climate Fund and theGovernment of Norway for reducing deforestation and emissions between 2014 and 2017. In 2020, there
was concern about the sustainability of such progress after the announcement of government programs
designed to counter economic slowdowns caused by the COVID-19 pandemic. Indonesia’s Omnibus Law
on Job Creation, passed in October 2020, for example, weakens environmental protections and laws related
to land use and consultation (Siscawati 2020).
During the study period, Forest Trends estimates that 89 percent of Indonesia’s forest loss was driven bycommercial agriculture, almost half for oil palm plantations, the rest for pulp, rubber, rice, and a host of othercash crops. Of particular concern is the recent announcement of a 700,000 ha Food Estate project and a 9
Mha agricultural reform program, 4.1 Mha of which is to be “de-designated” from the protected Forest Estate.
A review by Indonesia’s Supreme Audit Agency concluded that 81 percent of oil palm concessions violated
one or more laws or mandatory management standards. A similar review has not been conducted forIndonesia’s other agricultural sectors – or at least not published – but there is evidence of widespread
illegality across these sectors as well. Examples of illegality include operating in protected areas, outside
concession boundaries, or without permits, and clearing peat forest protected by the peatland moratorium.
NGOs, like the Anti Forest Mafia Coalition, have prepared numerous reports on illegality in the commercial
agriculture sectors, and in 2018, Greenpeace severed its five-year relationship with Sinar Mas/Asia Pulp &Paper due to concern about fires in oil palm and pulp plantations. Indigenous Adat communities report
widespread violations of legal requirements for compensation and benefits sharing, not to mention FPIC.
This leads to conflict between communities and companies; the Government of Indonesia (2020) reportsthat 27 percent of pulp plantations do not have active management, often because of conflicts with locals.
Furthermore, corrupt politicians have used concession permits to improve their chances in local elections,and companies are avoiding deforestation taxes and other fees.

ASIA-PACIFIC REGIONAL SUMMARY|

MAY 2021

Given these reported violations, it is clear that illegality linked to agro-conversion is widespread. Almost halfof Indonesia’s production of these commodities are exported. Exports linked to deforestation include 12 Mt
of palm oil (worth US$6 billion in 2019 alone), US$3 billion worth of pulp, and US$2 billion of paper.
Similar dynamics occur across Malaysia at a smaller scale; 3.3 Mha of forest was lost between 2013 and 2019,or 4 percent of all forest loss across the tropics (fourth overall). Almost all of this forest loss was reportedly driven
by commodities, two-thirds by oil palm. Pulp plantations, rubber, rice, and other crops comprised the rest.
Patterns were similar across Peninsular and Bornean Malaysia. Logging concessions have been granted during
the COVID-19 pandemic, reportedly in violation of FPIC requirements.15 Like Indonesia, reports of illegality related
to forest clearing are widespread, but there have been no legal reviews of the sector (other than a review by
the Sabah Forestry Department that found only two-thirds of 37 Forest Management Units, allocated to morethan 1.8 Mha, could meet even the minimum standards. Four had to be terminated altogether). Given that
commodities drive almost all deforestation, a comprehensive review would help evaluate the actual rate ofillegality across the sector. Regardless, in 2019, Malaysia exported at least US$6.5 billion in palm oil, US$9.6
million in pulp, and US$726 million in rubber, all linked to deforestation, much of it potentially illegal.

MEKONGThe Mekong countries lost 7.2 Mha of forest between 2013 and 2019, or 30 percent of all of Asia-Pacific’s
forests, of which 69 percent was likely driven by commercial agriculture.
Myanmar lost almost 2 Mha of forest, almost 5 percent of its forest cover between 2013 and 2019. Forest
Trends estimates that 68 percent was driven by expansion of commercial agriculture. Over the past twenty
years, agricultural licenses have reportedly been used to gain access to conversion timber, often without
any intention of developing an agricultural concession, and the issuing government agencies use legal
loopholes and exemptions to bypass the legal intent. The Government has allocated over 2.1 Mha in agriculturalconcessions by 2013, but less than half were being cultivated a few years later, suggesting that conversion
timber and land grabbing were likely the real motivation. In the Tanintharyi Region, 1.9 Mha have been
allocated to palm oil plantation companies, while Mon, Tanintharyi, and Kayin account for 68 percent of thearea under rubber.
The main crops embodying deforestation are rice, maize, pulses, and beans, grown mostly for the domestic
markets. Specific cases of illegality have been documented, such as clearing more than the maximum
permitted area, failing to start cultivation within the legally required timeframe, or the payment of bribes, but
no formal review has been published. A comprehensive compliance audit of the sector would help to establish
the actual rate of compliance with national laws and regulations. Even before the coup in February 2021,
buyers reported difficulties undertaking due diligence to ensure no illegally harvested wood products enter
their supply chains, and the same will hold true for efforts to assess and mitigate the risk of buying commodities
associated with illegal deforestation.
Cambodia has experienced vast and rapid destruction of its forests: reduced from 73 percent of the country’s
area in 1965 to 46 percent by 2020. Forest Trends estimates that 89 percent of forest loss between 20132019 has been driven by commercial agriculture, both large and small-scale. From 2001, the Cambodian
Government granted up to 2.6 Mha for large scale agriculture for export, but reversed course in 2012, when
it put a moratorium on new Economic Land Concessions (ELCs) and partially revoked poorly performing
15

More details on FPIC requirements in Malaysia and other countries that have incorporated it into law can be found in Annex 2.

43

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

ones, reducing their total extent to 1.2 Mha. Forest cover in ELCs had been reduced to 16 percent by 2017,
but forest everywhere in Cambodia is under threat, even in protected areas. For example, 70 percent of theSnoul Wildlife Sanctuary was illegally converted to rubber plantations (Warren-Thomas et al. 2015).
Agriculture by smallholders is also a major cause of forest loss, largely driven by the migration of land-poor
farmers from the lowlands to the peripheral uplands (Ingalls et al. 2018). More forest has been cleared for rice,cassava, soy, beef, and maize than for rubber, and 16 percent of commodities embodying deforestation areexported (Pendrill et al. 2020). Illegality is high for any commodity produced in ELCs as these are widely
recognized to be “mechanisms for the Cambodian ruling elite to enable land grabbing, clear-cutting and sellingof high value timber,” and only a few are compliant with requirements to have Environmental Impact Assessments(Beauchamp et al. 2018; Open Development Cambodia 2020). Converting forest to agriculture is also used togain land title in the forest frontier areas of Cambodia – timber extraction subsidizes new crops, and planting
demonstrates active use of land that is required to gain title. The primary objective is to sell the land rather thanto farm it. There has been a rush of seizures of public forest land, and speculation by powerful outsiders has
driven the purchase of public forest and turned it into private agricultural land (Mahanty & Milne 2016).
Like Cambodia, Laos has promoted the agricultural concession model for economic development, withcorresponding high levels of deforestation. Laos has lost nearly 2 Mha of forest between 2013 and 2019,and commercial agriculture has been a major driver, causing 56 percent of Laos’ forest loss during this time.
Non-compliance with national laws and regulations are estimated at 98 percent of all concessions and leases,
based on a review of legal compliance with six fundamental aspects of the legal framework (Hett et al. 2020).
Many aspects of illegality are documented, such as corruption and bribery in granting concessions, size
exceeding maximum limits, lack of environmental impact assessment, failure to pay compensation due tovillagers, and clearance of forests beyond concession boundaries. Illegality of smallholder agro-conversion
is not well documented and requires further research. Forest Trends conservatively estimates that 49 percent
of agro-conversion is illegal, based on land leases and concessions, which account for roughly half of Laos’forest loss. This assumes a “best case scenario,” in which all the deforestation occurring outside theseconcessions and leases is legal. In reality, it is likely that at least some – albeit a presently unknown amountof – agricultural land formerly zoned as forestland was illegally converted.
Rice is the main deforestation risk commodity, but it is consumed domestically. Among the other commodities
embodying deforestation, such as maize, sugar, and coffee, exports are low, with about 20 percent of
production likely exported overall.
Vietnam is unusual in the region with a net increase in its forest area to 14.6 Mha in 2020, according togovernment definitions. Forty-seven percent of the country is now covered in forest, up from 13.4 Mha in2010 (FOA FRA 2020). Despite this overall net increase, Vietnam still suffered a gross loss of 1.4 Mha offorests between 2013 and 2019 (GFW 2020). Vietnam’s forest sector was reformed and decentralized shortly
after its move to a market-oriented economy, and by 2015 the state claimed ownership of 45 percent of thecountry’s forest, down from 80 percent in 2000 (Open Development Mekong 2020). Wood plantations(mainly Eucalyptus and Acacia varieties) were a large driver of deforestation in the 1990s, while native varieties
have been promoted more recently by the government. The area of land planted with rubber expanded
between 2013 and 2019, increasing by over 140,000 ha (FAOSTAT 2020). The Central Highlands havesuffered rapid deforestation during this period, partly the result of large government-backed programs to
support migration from the lowlands. The migrants work on coffee and cassava plantations (probably legallyde-zoned forestland), and in turn displace the ethnic minority groups who move into the forest and clear it
for agriculture (probably illegal because they do not have land title certificates), making plantations indirectly
responsible for further deforestation.

ASIA-PACIFIC REGIONAL SUMMARY|

MAY 2021

OCEANIA
Papua New Guinea (PNG) had over 40 Mha of forest in 2019, covering 79 percent of the country. But 2
percent of its forest cover was lost between 2013 and 2019. Forest Trends estimates that 30 percent of thisforest loss was driven by commercial agriculture, but agricultural permits are being used to fraudulently gain
access to high-value conversion timber. Two types of permits, Forest Clearance Authorities (FCAs) and Timber
Authorities (TAs), allow clear cutting of forest for plantations, but in many cases, crops are never planted
because the loggers’ primary purpose is to export timber they would not otherwise be able to obtain logging
permits to access. High levels of illegality are likely, given that many of the FCAs and TAs are issued on thesame sites as Special Agriculture Business Leases (SABLs), which were mostly found to be illegal themselves
after a 2012 investigation by a Commission of Inquiry. Despite government promises to revoke all SABLs,
logging on these areas continued under the FCAs and TAs. Investigations by Global Witness found evidenceof widespread illegality; communities, who hold collective title, had not given their consent for their land to
be leased, and witness statements described threats and intimidation, pollution of water sources, and forest
clearing beyond the concession boundaries.
A high proportion of logs currently being exported out of PNG were harvested under agricultural permits.
In 2019, US$472 million of palm oil and US$7 million of rubber were exported, and there is a high risk thatthese exports were grown on illegally cleared land. As elsewhere in the Asia-Pacific region, buyers havestruggled to implement enhanced due diligence to ensure that purchased timber and commodities were
not contaminated by a link to illegal deforestation.

CONCLUSION
More than three quarters (76 percent) of deforestation in Asia-Pacific was driven by commercial agriculture.
Palm oil, pulp plantations, rice, beef, and rubber are the top commodities linked to deforestation. Across theregion, there are widespread cases of illegal agro-conversion but almost no publicly available compliance
audits that systematically evaluate illegality. Given the lack of data, Forest Trends could only confirm that atleast 41 percent of agro-conversion is illegal. However, this is likely a conservative figure, because in otherareas where comprehensive audits have been completed, non-compliance was found to be significantly
higher (e.g., in the oil palm sector in Indonesia, greater than 80 percent of agro-conversion was found to be
non-compliant).
Palm oil is the biggest forest risk commodity in Asia-Pacific. Between 2013 and 2017, it was linked to morethan 2.3 Mha of deforestation in the eight case studies reported here (Pendrill et al. 2020). Southeast Asia
has 80 percent of the world’s palm oil plantations – 38 percent of production in Indonesia was linked todeforestation, and 68 percent in Malaysia (Descals et al. 2020; Meijaard et al. 2020). While Indonesia’s
Supreme Audit Agency ruled that 81 percent of oil palm concessions broke the law or failed to comply withmandatory standards, in Malaysia no such review has been conducted and it is not possible to estimate howmuch clearance for palm oil has been illegal. However, both Indonesia and Malaysia have mandatory
sustainable palm oil standards and “No Deforestation, No Peat, No Exploitation” (NDPE) policies are being
implemented on 72 percent of their palm oil refining capacity (Chain Reaction Research 2020). In recent
years, the deforestation for oil palm appears to be decreasing. However, demand for vegetable oils ispredicted to rise, reinforcing the need to redouble efforts to halt forest clearance for oil palm (Descals et al.
2020).
Pulp plantations are also plagued with accusations of illegality, including widespread violations of indigenous

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

peoples’ rights. Abuse of indigenous and local communities’ land rights and land conflicts were found in all
the country case studies (Annex 3). Indonesia has experimented with the Jurisdictional Approach to moresustainable and equitable land use and this approach is seen as an opportunity to clarify rights and tenure,resolve disputes, and enforce sustainability requirements (Seymour & Harris 2020; Colchester et al. 2020).
Subnational initiatives such as this show promise at a time when national environmental legislation is weakened
in the name of COVID-19-related economic stimulus.
Asia-Pacific accounted for over half (53 percent) of all exported agricultural conversion between 2013 and2019, giving consumer countries leverage and the opportunity to limit the import of commodities grown on
deforested land. Given that so many agricultural commodities produced in Asia-Pacific are linked to agroconversion and carry a high risk of contamination with illegal clearing, consumer countries must practiceenhanced due diligence commensurate with this risk if they do not want to be complicit in the production
and distribution of illicit goods.

CONCLUSION

7|

MAY 2021

Conclusion

In summary, the evidence presented in this report reveals an ugly truth: illegal agro-conversion and thesubsequent illegality of agricultural commodities produced on that converted land remains a global problem
that has been getting worse.
While some geographies have taken tentative steps forward, others have experienced backsliding. To
date, the overall picture is that reaching zero agro-conversion is getting harder, not easier. The averageannual rate of tropical forest loss reportedly increased from about 7.3 Mha per year in the first 12 years of
this century to more than 10.9 Mha per year more recently (GFW 2020; using Hansen 2013). Forest Trends
found that 60 percent of this tropical forest loss (more than 6.5 Mha per year) was driven by commercial
agriculture, an increase of more than 28 percent in the average annual rate of agro-conversion over theprevious period (5.1 Mha per year), even though the proportion of deforestation attributable to agroconversion decreased somewhat (Forest Trends 2014). At least 69 percent of agro-conversion (at least
4.5 Mha per year) was conducted in violation of national laws and regulations, an increase of 28 percent
in annual rate (from 3.5 Mha per year from 2000 to 2012).
This rate of forest loss need not and must not continue. There is already enough land in agricultural
production worldwide to provide a healthy diet to a growing human population for decades into the future(EAT 2019); the services forests provide to people are too valuable and irreplaceable to keep sacrificing(Dasgupta 2021); and countries cannot meet global climate goals without dramatically reducing deforestation(Griscom et al. 2017).
While the findings of this report seem dire, there is hope for successful governance and rule of law in theland sector. Hope comes from many directions and proves what is possible, from Brazil’s success in the
2000s reducing deforestation and Indonesia’s more recent progress resulting in significant international
compensation for its emissions reductions, to the continued leadership from some corners of industry andan increasing global political focus on natural climate solutions.
These examples are good reminders that successful governance and rule of law in the land sector are
hard-won but possible on national scales. However, the commercial agriculture sector in the tropics stillneeds to undergo a serious transformation towards legality. In a forthcoming report, Forest Trends willpropose a path forward for curbing illegal land-use change and advancing forest country objectives forzero deforestation. In the meantime, this report shows that too much of the world’s agricultural production
and trade carries a high risk of including illicit harvests, leaving companies and their customers complicitin tropical forest loss and trafficking in illegal products.

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

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13, 7. pp 4028. iopscience.iop.org/article/10.1088/1748-9326/aacd1c.
United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). 2013. A Manual for Human Rights
Institutions. Sydney: Asia Pacific Forum and Geneva: Office of the United Nations. www.ohchr.org/
documents/issues/ipeoples/undripmanualfornhris.pdf.
United Nations Panel of Experts. 2013. “Letter dated 19 November 2013 from the Chair of the Security Council
Committee established pursuant to resolution 1521 (2003) concerning Liberia addressed to the
President of the Security Council.” New York, USA: United Nations. www.securitycouncilreport.org/
atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2013_683.pdf.
UN-REDD Programme. 2016. “Videos: Episode 2: Madagascar (REDD+ and the future of African Forests).”
www.unredd.net/library/multimedia/videos/1192-episode-2-madagascar-redd-and-the-future-of-africanforests.html.
Vallejo Larios, Mario. 2011. Evaluación Preliminar sobre Causas de Deforestación y Degradación de Bosquesen Honduras. Programa Regional REDD. Accessed March 16, 2021. www.reddccadgiz.org/documentos/
doc_323022347.pdf.
Villavicencio Calzadilla, Paola and Louis Kotzé. 2018. “Living in Harmony with Nature? A Critical Appraisal

53

54

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTUREof the Rights of Mother Earth in Bolivia.” Transnational Environmental Law. 7, 3. pp. 397-424. DOI:
10.1017/S2047102518000201.
Volckhausen, Taran. May 30, 2019. “Land grabbing, cattle ranching ravage Colombian Amazon after FARC
demobilization.” Mongabay. Accessed February 18, 2021. news.mongabay.com/2019/05/land-grabbingcattle-ranching-ravage-colombian-amazon-after-farc-demobilization/
Warren‐Thomas, E., Dolman, P., and Edwards, D. 2015. “Increasing Demand for Natural Rubber Necessitatesa Robust Sustainability Initiative to Mitigate Impacts on Tropical Biodiversity.” Conservation Letters.
8,4. pp. 230-241. DOI: 10.1111/conl.12170.
Whyner, Daniel. 2021. Personal communication. US Agency for International Development (USAID).
Zegarra Méndez, Eduardo and Juan Pablo Gayoso. 2015. Cuarto capítulo. Cambios en la agricultura ydeforestación en la selva peruana: análisis basado en el IV Censo Agropecuario. Buenos Aires,
Argentina: Consejo Latinoamericano de Ciencias. Accessed March 31, 2021. Socialesbiblioteca.clacso.
edu.ar/Peru/grade/20160218014001/Cap4LIBROGRADE_CENAGRO.pdf.

ACRONYMS|

MAY 2021

Acronyms
BRG

Badan Restorasi Gambut (Peat Restoration
Agency, Indonesia)

UNDRIP

United Nations Declaration on the Rights ofIndigenous Peoples

CAR

Cadastro Ambiental Rural (Rural Environmental
Registry of Brazil)

USDA

United States Department of Agriculture

CO2

Carbon dioxide

CO2eCarbon dioxide-equivalent (all gases)

DRC

Democratic Republic of Congo

ELC

Economic Land Concession (Cambodia)

EU

European Union

FAO FRA

Food and Agriculture Organisation of the United
Nations — Global Forest Resources Assessment

FCA

Forest Clearance Authority (Papua New Guinea)

FPIC

Free, Prior, and Informed Consent

FRC

Forest Risk Commodity

GAIN

Global Agricultural Information Network of USDA

GHG

Greenhouse gas(es)

GFW

Global Forest Watch

Gt

Gigatonha

HectareIDEAM

Institute of Hydrology, Meteorology andEnvironmental Studies (Colombia)

KPK

Komisi Pemberantasan Korupsi (Corruption
Eradication Commission of Indonesia)

ILO C169

International Labour Organization (ILO)
Convention 169

LAC

Latin America and the Caribbean

m3

cubic meter

Mha

Million hectares

Mtmillion metric tonnes

NDPE

No Deforestation, No Peat, No Exploitation

PRODES

Programa de Cálculo do Desflorestamento da
Amazônia (deforestation monitoring service,
Brazil)

PNG

Papua New Guinea

REDD+

Reducing Emissions from Deforestation andforest Degradation plus the sustainable
management of forests

SABL

Special-purpose Agricultural and Business
Leases (Papua New Guinea)

TA

Timber Authorities (Papua New Guinea)

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

56

Glossary>50% canopy: Tree cover of 51 percent or more is the threshold used in this report to define forest areas tokeep a focus on well forested landscapes that provide important ecosystem services locally (e.g., pollination,
maintaining water cycles, etc.) and globally (especially as carbon sinks helping mitigate climate change).
>50% tree cover loss: The loss of more than 50 percent of forest canopy.
Agribusiness: Large-scale agricultural businesses and their supply chains.
Agro-commodities: Commercially produced agricultural commodities, including crops, livestock, and products
from tree plantations.
Agro-conversion: Loss of forest driven by commercial agriculture.
Amazonia: Brazil’s Legal Amazon (see below).
Biodiversity hotspot: Region meeting two criteria of containing 1) at least 1,500 endemic vascular plants and2) 30 percent or less of its original natural vegetation. Thirty-six biologically rich, threatened regions areglobally recognized as biodiversity hotspots and comprise 2.4 percent of the Earth’s surface (Conservation
International 2020).
Brazil’s environmental debt: Areas defined under the Brazil 1965 Forest Code as Legal Reserve and Riparian
Preservation Areas that were deforested illegally before 2008 and would have required restoration at thelandowner’s expense (Soares-Filho et al. 2014).
Caatinga: Semi-arid biome in Northeastern Brazil, bordered by the Amazon, Cerrado, and Atlantic Forest
biomes.
Central Africa: Countries of Angola, Burundi, Cameroon, the Central African Republic, Chad, Democratic
Republic of Congo (DRC), Equatorial Guinea, Gabon, Rwanda, and the Republic of Congo.
Cerrado: Wooded savanna covering 12 vegetation types in Central Brazil and parts of Bolivia and Paraguay.
It borders the Amazon, Caatinga, Atlantic Forest, and Pantanal biomes.
Chaco: Sparsely populated, hot, and semi-arid lowland forest ecosystem of the Río de la Plata basin, divided
among eastern Bolivia, Paraguay, northern Argentina, and a portion of the Brazilian states of Mato Grossoand Mato Grosso do Sul. Second largest forest system in South America, after the Amazon.
Chiquitano: Dry forests of Bolivia and Brazil with trees that lose their leaves during the dry season and are
generally resistant to flooding and fire.
Congo Basin/Congo River Basin: Countries of Cameroon, the Central African Republic, the Democratic
Republic of Congo (DRC), Equatorial Guinea, Gabon, and the Republic of Congo.
CO2e emissions: This report quantifies the amount of greenhouse gas emissions (expressed in mega-tonnes(Mt) of carbon dioxide equivalent emissions) caused by tree cover loss, as reported by Global Forest Watch(2020, using methodology from Harris et al. 2021).
Commercial agriculture: Large- or small-scale, including crops, pasture (mainly cattle), and monoculture
tree plantations. Excludes subsistence farming.

GLOSSARY|

MAY 2021

Community forestry: Forest operations where the local community plays a significant role in land use
decision-making and forest management. Communities may, depending on national legislation, possess abundle of rights (usually access, use, management, or full ownership) to land under community forestry.
Concession: A grant of land or property by a government or some other controlling authority to anotherlegal entity (usually a large company) in return for payment or services. Sometimes concessions are allocatedthrough a competitive process, such as auctions.
Conversion timber/wood: Timber generated during the conversion of natural forest areas to non-forest or
plantation use, such as the clearance of a forest to make way for commercial agriculture.
Deforestation: Complete removal of forest cover, which is defined in this Glossary as the removal of at least
51 percent of forest cover.
Deforestation alert: A report on a disturbance in the forest canopy that indicates a likely deforestation event.
Embodied deforestation: The amount of deforestation linked to the production of a given amount of an
agricultural commodity.
Endemic species: Plants and animals that are naturally found in only one geographic region on Earth.
Environmental Impact Assessment: A regulatory process used to predict the environmental consequencesof a plan, policy, program, or project, and develop a time-bound plan with specific objectives to mitigate
these consequences.
Forest/Forest cover: Forest areas with greater than 50 percent tree cover that are greater than five meters
tall.
Forest degradation: The process of human-caused loss of forest biomass, resources, and environmental
services without a complete loss of forest cover.
Forest loss: The complete removal of forest cover (which is defined as forest areas with greater than 50
percent tree cover).
Fraud: In law, the act of intentionally deceiving someone in order to gain an unfair or illegal advantage (financial,political, or otherwise). Countries usually consider such offenses to be criminal or a violation of civil law.
Free, Prior, Informed Consent (FPIC): The right of communities (particularly of indigenous peoples) to giveor withhold their “consent” for any action that would affect their lands, territories, or rights (including thosethat affect customary ownership, occupation or other use). “Free” indicates that consent cannot be given
under force or threat. “Prior” indicates that relevant information must be provided with enough time to review
it before consent is decided. “Informed” means that the information provided is timely, detailed, emphasizes
both the potential positive and negative impacts of the activity, and is presented in a language and format
understood by the community. “Consent” refers to the right of the community to agree or not agree to theproject before it commences (UNDRIP 2013).
Gross deforestation: Loss of forest cover, without consideration of regrowth or reforestation.
Illegal deforestation: Conversion of forest that takes place in contravention of a country’s legislative framework(laws, regulations, instructions, and any other legal instrument that penalizes non-compliance) at the time thedeforestation took place. For purposes of this report, conversions that were “legalized” after the fact (throughamnesties, legal amendments, for example), after prosecution, or by paying a fine, are not considered tohave been conducted in compliance with the rule of law. This report does not include breaches of international

57

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

law or customary law unless they are included in national statutory or case laws. This definition encompasses
two general categories: illegalities in licensing and illegalities in forest clearance.
Land grabs: As defined by the Tirana Declaration, large-scale land acquisitions that are one or more of thefollowing: in violation of human rights, particularly the equal rights of women; not based on FPIC; not basedon a thorough assessment, or in disregard of, social, economic, and environmental impacts, including theway they are gendered; not based on transparent contracts that specify clear and binding commitments
about activities, employment, and benefit sharing, and/or; not based on effective democratic planning,
independent oversight, and meaningful participation (Taylor 2012). Three categories of land grabs have been
identified: 1) Tainted lands is a term employed by the UN Special Rapporteur on the Right to Food to describe
land obtained “through corrupt means, such as bribing public officials or community leaders…, or failing toensure the land was acquired by the seller through legal and transparent means”; 2) forced eviction is definedbroadly by the UN Committee on Economic, Social and Cultural Rights as “the permanent or temporary
removal against their will of individuals, families and/or communities from the homes and/or land which theyoccupy, without the provision of, and access to, appropriate forms of legal or other protection;” and 3) projectinduced displacement refers to communities and individuals being forced out of their homes, and often their
homelands, for the purposes of economic development.
Large-scale commercial agriculture: Corporate- or family-owned holdings that are far above the national
average in size (only 3 percent of farms are larger than 10 ha worldwide) and employ a waged labour force(Lowder et al. 2016).
Legal Amazon: Brazilian states of Rondônia, Acre, Amazonas, Roraima, Pará, Amapá, Tocantins, Mato Grosso,
and Maranhão west of 44º W. It includes three biomes: all of Brazil’s Amazon biome, 37 percent of the Cerrado,and 40 percent of the Pantanal.
Legal Reserve (Brazil): As defined in Federal Law 12.651/2012, “areas located within a property or rural
possession, defined under Art. 12, with the function of ensuring sustainable economic use of the natural
resources of rural property, assisting the conservation and rehabilitation of ecological processes and promoting
the conservation of biodiversity, as well as sheltering and protecting native wildlife and flora.” All Brazilian
rural property owners are required to keep a certain percentage of their land in forest cover or its native
vegetation. These Legal Reserves should not be less than 80 percent of the total area of the property in the
Amazon biome, 35 percent in the Cerrado, and 20 percent in other biomes. They must also be included in
Brazil’s Rural Environmental Registry (CAR).
Net deforestation: Gross deforestation minus the area in which regrowth/reforestation has occurred.
Pantanal: Wetlands biome in Brazil’s Mato Grosso and Mato Grosso do Sul, bordering on Cerrado, Atlantic
Forest, Chaco, and Chiquitano.
Permanent Preservation Areas (Brazil): As defined in Federal Law 12,651/2012, “a protected area covered
or not by native vegetation, with the environmental function of preserving water resources, landscapes,
geological stability and biodiversity, facilitating gene flows of fauna and flora, protecting the soil and ensuring
welfare of human populations,” which must be demarcated within all rural properties in Brazil and includedin the Rural Environmental Registry (CAR).
Program to Calculate Deforestation in the Amazon (PRODES, Brazil): The government satellite monitoring
program that produces data that are considered Brazil’s official national statistics on deforestation. PRODES
Amazon monitors clear cut deforestation between August 1 to July 31 each year in the Brazilian Legal Amazon.
PRODES Cerrado monitors deforestation in the Cerrado biome, but excludes the areas overlapping the Legal
Amazon. PRODES Amazon detects deforestation of areas larger than 6.25 ha in forests classified as primaryGLOSSARY|

MAY 2021

forest. PRODES Cerrado detects the deforestation of primary forest, savannas, and grasslands (or classified
as such since 2000) from areas larger than one ha.
Plantation timber/wood: Forest products obtained from areas established by planting and/or artificiallyseeding, as opposed to those originating from natural forests.
Quilombola: Descendants of Afro-Brazilian slaves in Brazil.
Tree Cover Loss: Stand level replacement of vegetation greater than five meters tall.
Tropical forest: All forest found in tropical areas. Tropical forests represent less than 15 percent of the Earth’s
terrestrial surface yet support more than half of the planet’s species. They also play a disproportionately
large role in determining climate due to the vast amounts of carbon and water they store and exchange withthe atmosphere (Reed et al. 2020).

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60

Appendices
Appendix 1 Methodology
This study estimates illegal deforestation for purposes of commercial agriculture in the tropics, and associatedexports of key agricultural commodities from 2013 to 2019. More specifically:● The amount of tropical forest loss that was driven by agricultural commodities, linked to illegal clearing,and exported. All findings were then converted into estimates of greenhouse gas emissions.
● The amount of exports that are linked to deforestation and are at risk of contamination by illegal clearing.
Data from 2019 was used to calculate the volume and value of exports of the ten major agro-commodities
linked to deforestation and/or risk contamination by illegality: beef and leather, palm oil, soy, pulp andpaper, rubber, cocoa, coffee, and maize.

PART 1
Estimating illegal deforestation for commercial agriculture andassociated trade
To estimate tropical deforestation driven by the illegal clearing of forest lands for commercial agriculture andthen calculate associated trade of agricultural commodities, Forest Trends followed the following steps:

Step 1: Estimating tropical forest loss, 2013-2019 (Variable A)
Collecting the most recent data available from 2013 to 2019 on area of forest lost in tropical countries was
the first step in estimating the area of tropical forest lost due to illegal commercial agriculture.
“Forests” were defined as lands having more than half of their area covered by vegetation taller than fivemeters.16 This focuses findings on well forested landscapes (like primary forests) that provide important local
and global ecosystem services. “Deforestation” was defined as the complete loss of trees in a forested area.
Deforestation and forest loss are used interchangeably.17 The report also covers all forest types found intropical countries, not only tropical rainforests but others such as the dry forests of the Brazilian Cerrado or
the Gran Chaco of South America.

There are more than 800 definitions of forests in the literature (Harris et al. 2016). For example, FAO FRA (2020) coverage ofBrazil defines forests as having at least 10 percent tree cover, and Pendrill et al. (2019) use a 25 percent threshold. Plantations
were included in Forest Trends’ definition as their loss has impacts on many ecosystem services that will not be replaced foryears (e.g., as a carbon sink that will not recover until the plantation begins to mature).
17
This study also defines deforestation differently from others. For example, FAO FRA (2020) defines deforestation “as theconversion of forest to other land uses (regardless of whether it is human-induced).” Curtis et al. (2018), in contrast, define
deforestation as the permanent conversion of forest by humans to agriculture, mining, energy infrastructure, and urbanization,although they exclude shifting cultivation (subsistence agriculture). Their definition aims to differentiate deforestation driven byhuman causes from natural forest loss, and to differentiate temporary loss (to wildfire, for example) from permanent conversion(to commercial agriculture, for example). Forest Trends chose not to make such a differentiation in this study. Given that the
final year of analysis is 2019, it is too soon to draw conclusions about the permanence of any forest loss. This is why deforestation and forest loss are used interchangeably in this report.
16

APPENDIX 1|

MAY 2021

Figure A1 | Loss of tropical forests with over 50 percent tree cover, 2013-2019

Notes: Green shading indicates forest cover in 2010. Red shading indicates forest loss since 2013.
Source: GFW 2020, using Hansen et al. 2013

The amount of forest loss for each tropical country was obtained from the Global Forest Watch (GFW 2020)
database of annual change in tree cover between 2013 and 2019, inclusive for all forests with greater than
50 percent canopy cover – both primary and secondary forests and plantations (Figure A1). Plantations were
8 percent of all forest loss over this period.
The GFW data is based on the methodology of Hansen et al. (2013), which measures tree cover loss at
approximately 30 by 30 meters of resolution, generated “using multispectral satellite imagery from the Landsat
5 thematic mapper (TM), the Landsat 7 thematic mapper plus (ETM+), and the Landsat 8 Operational Land
Imager (OLI) sensors…[T]he satellite images were assembled and a supervised learning algorithm was applied
to identify per pixel tree cover loss.”
Forest Trends corroborated overall results by substituting it with FAO FRA (2020) forest loss data. FAO FRA
reports deforestation annually since 2015, and every five years before that. Thus 60 percent of forest lostfrom 2010 to 2015 was used to estimate loss for 2013 to 2015. (Note: For the few countries where FAO FRA
does not report deforestation, net change in forest cover was used instead.)

Step 2: Estimating percentage of forest loss linked to commercial agriculture (Variable B)
The second step was to estimate the percentage of tropical forest loss that was driven by commercial
agriculture during the reference period (2013-2019).
The study defines “commercial agriculture” as crops, pasture (mainly cattle), and monoculture tree plantations,
whether large- or small-scale, but excludes land used for subsistence farming.
The study used the GFW (2020) database, which uses the methodology of Curtis et al. (2018) for drivers offorest loss in each country. However, for the countries most affected by deforestation, Forest Trends conducted
23 country studies (Annexes 1-3). This is because Global Forest Watch may underestimate the importanceof commercial agriculture as a driver of tropical forest loss (Box A1). It was also important to recognize that
all forest monitoring systems have challenges based on data availability, scale of applicability, scope, andmethodology. Thus, for those countries that comprised at least 85 percent of all tropical forest loss, 18 Forest
Trends reviewed the literature and spoke to experts to obtain more accurate estimates of national driversof deforestation. These country case studies include the 23 countries – 21 countries19 with the most forest
loss and Honduras and Ghana (selected for further commodity analysis). The 101 countries that comprise the“rest of the world” made up the remaining 13 percent of tropical forest loss.20
According to FAO, these countries comprise 87% of all of the tropical forest loss from 2013 to 2019.
Papua New Guinea was included in the report to maintain consistency and allow comparision with Forest Trends’ 2014 report“Consumer Goods and Deforestation.”
20
According to FAO, (which differs from GFW in definition of both forests and deforestation) the countries categorized in thisstudy as the “rest of the world” comprise 29% of all of the tropical forest loss during 2013-2019.
18

19

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ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

62

BOX A1

Challenges in Using Forest Monitoring Data
The GFW and Hansen methodologies aim to provide an unbiased proxy for tropical deforestation
using a globally consistent forest definition and methodology (Harris et al. 2018). Over time, satellite
imagery has drastically improved abilities to monitor changes in forest cover, but such changes
complicate evaluating temporal (longitudinal) trends.
In 2015, GFW began to use “images from Landsat 8, a new generation of the satellite launched byNASA in 2013. The sharp new Landsat 8 images, combined with Landsat 7, helped re-calibrate themapping algorithms to be more sensitive to change.” (Potapov et al. 2015) GFW was able to combine
new algorithms to revise data, using images obtained back to 2011. These advances improved, forexample, detection of clearing of short cycle plantations and, in Brazil, rotation in forest plantations
and clearing of the Cerrado. On the whole, the changes increased the amount of deforestation
detected compared to previous analyses, but “the reprocessing of 2011 and 2012 involves different
data and techniques than those from the original 2001-2010 data, and therefore users should becautious when comparing across those time periods” (Potapov et al. 2015). This also means thatcaution should be used if comparing the results in this report (covering 2013-2019) to those of theinitial Forest Trends (2014) report (which covered 2000-2012).
Differences between GFW/Hansen and FAO FRAFAO Forest Resources Assessment (FRA) reporting is based on “the best available official statistics”
submitted by sovereign governments and is not spatially explicit (FAO 2014), whereas GFW is basedon analysis of satellite imagery (described above). Moreover, the two definitions of forest differ (Harris
et al. 2016); GFW is expansive (as noted above, it covers all trees, including oil palm plantations, forexample), whereas FRA’s definition of forests includes land designated as “forest use,” even if it is
temporarily devoid of trees (e.g., areas recently logged or burned). Therefore, FRA requires permanent
forest loss to be considered deforestation, whereas GFW focuses instead on tree cover loss (temporary
or otherwise). “Critics of FRA claim that FAO’s “net forest change” statistic provides an overly optimistic
view of global forest trends, since loss of natural forests, rich in biodiversity and carbon, can be offset
by expansion of tree plantation monocultures. Meanwhile, critics of GFW claim that satellite-based
monitoring of “tree cover loss” creates an overly pessimistic view, since these data lump together
permanent and temporary loss of tree cover within natural forests and tree plantations and do nottake into account tree cover gain.” (Harris et al. 2016)
Using GFW and Hansen data for this report means findings may be conservative
Overall, it is likely that in many areas in the tropics, the GFW estimate of the importance of commercial
agriculture as a driver of tropical deforestation is generally conservative. There are four major caveats
regarding the accuracy of GFW’s measures of the drivers of deforestation used in this analysis:(continued)

APPENDIX 1|

MAY 2021

Challenges in Using Forest Monitoring Data (continued)

1) GFW’s commodities category does not overlap completely with this report’s focus on commercial
agriculture. The GFW dataset assigns the dominant driver of forest cover loss at a 10-kilometer (km)resolution, classifying forest cover loss occurring in each grid cell as either commodity-driven
deforestation, shifting cultivation, forestry, wildfire, or urbanization (Goldman et al. 2020). The definition
for commodities includes all commodities, not just those from commercial agriculture. However, thenon-agriculture component (e.g., mining), is likely a relatively small footprint compared to agriculture(e.g., in Indonesia, between 2001 and 2016, mining contributed only 2 percent of deforestation(Austin et al. 2019)). So, while the GFW commodities category may not overlap perfectly withcommercial agriculture as defined in this report, any over-estimation is likely to be small.
2) GFW recognizes that the accuracy of their drivers-algorithm varies regionally (Table S6 in Curtis etal. 2018). For example, while 94 percent of the area classified as commodity-driven deforestation
was reportedly accurate for Latin America, in Africa only 31 percent of the area classified as commoditydriven was accurate, mainly because the model misidentified 42 percent of the forest loss as due
to shifting agriculture, rather than driven by commercial agriculture. The Hansen data also mayunderestimate the conversion of dry forest and woody savannah, like the Cerrado and Chaco inSouth America (Goldman et al. 2020). All this makes the GFW drivers database a conservative
estimate of the importance of commercial agriculture in driving national patterns of deforestation.
3) Hansen datat may miss small openings caused by the production of commodities, like cocoa andcoffee, which often occur on very small (<1 ha) farms (Goldman et al. 2020). This too may cause
GFW to underestimate deforestation driven by commercial agriculture.
4) There is often a time lag between forest clearing and subsequent land use, as it takes time forplanting and the growth of crops to become of a sufficient size to be detected using satellite imagery(e.g., Pendrill et al. (2019) and the examples therein of the lag between forest clearing and theestablishment of crops, like soy in Brazil and oil palm plantations in Southeast Asia). This too may
make the GFW drivers data conservative — with a longer time span, it may become clear that moreforests have indeed been cleared for (as yet unplanted) commercial agricultural commodities.
Note: While not directly relevant to this study, the Hansen et al. data does not assess the area of forest degradationeach year.

Key sources of information on drivers of deforestation for the country studies include national REDD+ reportingand Pendrill et al. (2019, updated with data to 2017), who used a “land-balance model that quantifies
deforestation embodied in production of agricultural and forestry commodities at country level across thetropics.” This data also combines forest loss and crop expansion data, which Pendrill et al. used to calculate
the proportion of forest loss embodied in crops (covering 2013-2017), as a proportion of all forest loss (GFW
2020, using Hansen et al. 2013).

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64

Step 3: Estimating percentage of forest conversion driven by commercial agriculturethat was likely illegal (Variable C)
In this report, legality is framed in the context of recognizing each country’s sovereign rights. “Illegality” istherefore defined as the conversion of forests that takes place in contravention of a country’s legislative
framework, including its laws, regulations, instructions, and any other legal instrument that penalizes noncompliance. International treaties are not included in this definition unless they have been incorporated into
national law.
For each of the country studies, the literature was reviewed to evaluate compliance of forest clearing withthe relevant legislative framework at the time the deforestation took place. Clearing was, therefore, consideredillegal even if it was “legalized” after the fact by, for example, legal settlements, legal amendments, oramnesties (where a fine may be paid, etc.). While countries may have the sovereign right to retroactively
legalize deforestation, it remains true that, at the time of forest loss, the clearing was not conducted incompliance with the rule with law and was, therefore, illegal.

Step 4: Calculating tropical forest loss driven by agro-commodities linked to illegal
conversion
The product of Variables A, B, and C provided a best estimate of the area of tropical forest lost to agrocommodities linked to illegal conversion for each country (Equation 1).
Equation 1: Formula used to calculate area of tropical forest loss due to illegal conversion for commercial
agriculture, 2013-2019
Tropical forest
loss, 2013-2019
(Mha)

A

% of loss driven
by commercial
agricultureB% of loss
likely illegal

C

Area of tropicalforest loss due
to illegal
commercial
agriculture(Mha)

For the 23 countries that comprised 87 percent of all tropical forest loss, Forest Trends used the case studies(Annexes 1-3) to derive best estimates of Variables A, B, and C. The following data were used for the “restof the world” not covered by the in-depth studies:● Variable A: GFW (2020, using Hansen et al. 2013)● Variable B: GFW (2020, using Curtis et al. 2018)● Variable C: regional averages, depending on whether the country was in Africa, Asia (including Oceania),or Latin America (including the Caribbean)
Using sensitivity analyses on estimates of illegality
To test the implication of using regional averages for Variable C for the “rest of the world,” Forest Trends
conducted a sensitivity analysis by substituting a “best case scenario,” where illegality was assumed to be
0 percent and a “worst case scenario,” where illegality was assumed to be 100 percent. Given that the restof the world comprised only 13 percent of tropical deforestation, it was assumed that there would not bemuch difference among the three scenarios.
This sensitivity analysis also allowed Forest Trends to examine the impact of the lack of data available on

APPENDIX 1|

MAY 2021

compliance (Variable C) for many case study countries. In order to deal with insufficient evidence, countries
were divided into three categories (Table A1):
● High quality estimates: Rigorous empirical evidence supports accurate and precise estimates.
● Medium quality estimates: Evidence is sufficient to support a range for the variable, but not a precise
estimate.
● Insufficient data: Evidence is not sufficient to make any estimate.

Table A1 | Availability and quality of data for 23 country studies
DATA QUALITY
High
Countries

Brazil, Colombia, Mexico,
Democratic Republic ofCongo, Madagascar

MediumInsufficient

Argentina, Paraguay, Peru,
Indonesia, Cambodia, Laos,
Papua New Guinea, Thailand,
Liberia, Côte d’Ivoire, Ghana

Bolivia, Honduras, Malaysia,
Myanmar, Vietnam, Angola,
Sierra Leone

Note: See the individual country studies (Annexes 1-3) for detailed explanations of available data.

Thus, for the sensitivity analysis, the study parameterized Variable C for each of the 23 in-depth country
studies depending on their data quality (Table A2).

Table A2 | Treatment in sensitivity analyses of the 23 country studies depending on the quality of available data
for estimating the risk of illegality linked to agro-conversion
DATA QUALITYHigh
SCENARIOS

MediumInsufficient

Treatment for estimating variables

Best case

Point estimate

Low end of range

0%Best available evidence

Point estimate

Low end of range

Regional mean

Worst case

Point estimate

High end of range

100%

Note: See Annexes 1-3 for detailed explanations of point-estimates or ranges used for each country.

Step 5: Percentage of agro-commodities linked to deforestation that were exported(Variable D)
The primary source of data for Variable D was the Pendrill et al. (2019) analysis of embodied deforestationand country of consumption (domestic vs. export). For commodity-specific analysis in each country study,
the proportion of production exported was calculated with production data from the United Nations Food &Agriculture Organization (UN FAO) and trade data from the UN’s International Trade Statistics Database (UNComtrade). For some countries where detailed and rigorous analyses of the proportion of deforestation
driven by different crops were available, Pendrill et al. data was not used. Instead, the amount of deforestation

65

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

66

embedded in the trade was weighted by the size of each commodities’ trade and its link to deforestation.
For the “rest of the world,” embedded deforestation was based on the database from Pendrill et al. (2019).

Step 6: Calculating tropical forest loss driven by agro-commodities for export
The product of Variables A, B, and D provides Forest Trends’ best estimate of the area of tropical forest lost
due to agro-commodity production for export markets (Equation 2).
Equation 2: Formula used to calculate tropical forest loss driven by exported agro-commodities, 2013-2019
Tropical forest
loss, 2013-2019
(Mha)

A

% of loss driven
by commercial
agricultureB% of loss thatwas exportedD

Tropical forest
loss due to agroconversion forexport (Mha)Step 7: Estimating emissions from agro-commodity conversion (Variable E)
To estimate how forest loss translates into greenhouse gas emissions, this report estimated the amount ofcarbon dioxide-equivalent (CO2e) emissions from forest loss, which is based on analyses by Harris et al. (2021).

PART 2Estimating the quantity and value of exports from converted forestland
Forest Trends estimated the quantity and value of exports in 2019 for specific agricultural commodities thatoriginated from converted forestland: beef and leather, palm oil, soy, pulp and paper, rubber, cocoa, coffee,
and maize (Equation 3). Deforestation linked to this trade was tracked over the last 30 years (since ~1990),
not just on land cleared of forests since 2013. Only the study countries that are major traders of thesecommodities are included (Table A3). The study then examines the risk that the deforestation was contaminatedby illegal conversion.

Step 1: Estimating quantity and value of exports (Variable F)
For each relevant commodity and country, 2019 trade data was obtained from UN Comtrade.

Step 2: Estimating percentage of production coming from agro-conversion (Variable G)
The proportion of production for each commodity that originated from land cleared of forest was obtained
from the literature (Variable B). Estimates of deforestation prior to 2013 were obtained from Forest Trends(2014). Given that this analysis does not include any forest clearing prior to 1990, the results can beconsidered conservative.

Step 3: Estimating the risk of agro-commodity contamination by illegal agro-conversion
Illegality was evaluated for the deforestation associated with the commercial agricultural commodities (Variable
C). When production of a commodity is widespread across the country, Variable C (the estimate of illegality
from above) was used. When a product is grown in a specific region (such as Paraguayan soy grown in theeastern Atlantic Forest region that has a Zero Deforestation Law) then the illegality estimate is commodity
specific. Forest Trends (2014) and other literature provided estimates of illegality for land cleared prior to 2013.

APPENDIX 1|

67

MAY 2021

Equation 3: Formula used to calculate tropical forest loss embodied in agro-commodity exports,
2013-2019For each commodity, for each major producing country
Total volume orvalue of exports(tonnes or US$)F

% of production
from land
converted fromforests since 2000

G

Total volume orvalue of exports
linked to
deforestation(tonnes or US$)

Table A3 | Major traders of evaluated commodities
Soy

Beef & Leather

Palm Oil

Pulp & Paper

Rubber

Cocoa

CoffeeMaize
Argentina

BrazilBrazilMalaysia

Malaysia

Indonesia

Côte d’Ivoire

Honduras

Argentina

Argentina

Indonesia

Indonesia

Malaysia

Ghana

Côte d’Ivoire

Paraguay

Paraguay

Peru

Bolivia

MexicoCambodia
Laos
Vietnam
Democratic
Republic ofCongo (DRC)

VietnamILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

68

Appendix 2 Tropical countries by region, governance score (Forest

Trends 2019), and date of ratification for International
Labour Organization Convention 169 (ILO C169 - Indigenous
and Tribal Peoples Convention, 1989 [No. 169]); case study
countries highlighted

Latin America & the Caribbean

AfricaCountry

Forest Trends
governance score

Date of ratificationof ILO C169

Brazil61.3

25-Jul-02

DRC

95.5

Argentina

53.8

03-Jul-00

Angola84.9

Paraguay

59.5

10-Aug-93

Madagascar

78.1

Bolivia80.6

11-Dec-91

Liberia

83.4

Country

Forest Trends
governance score

Colombia

47.7

07-Aug-91

Sierra Leone

77.9

Mexico56.3

05-Sep-90

Côte d’Ivoire

67.7

Peru

46.7

02-Feb-94

Ghana

48.8

Honduras

71.4

28-Mar-95

Burundi

93.1

Aruba

25.4

Benin

64.6

Anguilla

17.5

Burkina Faso

64.3

Antigua and

34.9

Botswana

28.7

Central African Rep.

93.1

BonaireBahamas34.3

Cameroon

86.5

Saint Barthélemy

65.0

Republic of Congo

90.5

Belize40.4

Comoros

81.6

Bermuda31.6

Cape Verde

38.8

Barbados

30.3

Djibouti

72.8

Costa Rica

65.8

Eritrea

94.2

Cuba

31.6

Ethiopia

80.6

Bermuda

30.3

Gabon

73.8

Barbados

65.8

Guinea83.1

Costa Rica

30.3

Gambia

65.7

Cuba

65.8

02 Apr 1993

Curaçao
Cayman Islands

28.7

Dominica

37.3

Dominican Republic

59.9

Ecuador

68.9

25-Jun-02
15-May-98

Guadeloupe

Guinea-Bissau

89.0

Equatorial Guinea

90.6

Kenya

68.6

Maldives

65.4

Mali

79.9

Mozambique

81.6

Mauritania

79.4

Grenada39.5

Guatemala65.1

French Guiana

17.3

MayotteGuyana58.8

Namibia(continued)

05 Jun 1996

Mauritius

21.2

Malawi69.9
39.9

Date of ratificationof ILO C169

30-Aug-10

02 Apr 1993

25-Jun-02
15-May-98

05 Jun 1996

APPENDIX 2

Asia-PacificCountry

Forest Trends
governance score

Indonesia

49.8

Malaysia

29.4

Myanmar84.0

Cambodia

81.3

Vietnam

57.4

Laos

77.7

Papua New Guinea

69.9

Thailand

44.1

Bangladesh

78.6

Brunei32.1

Bhutan

33.5

Fiji

44.9

Micronesia (Federated

58.1

India

51.0

Kiribati

65.8

Sri Lanka

55.8

Macao

23.7

Myanmar84.0

Date of ratificationof ILO C169

03-Mar-98

New Caledonia
Nepal

64.3

Philippines

60.6

Palau

51.5

Singapore

6.3

Solomon Islands

62.9

East Timor

73.3

Tuvalu31.5

United States Minor
Vanuatu

46.0

14-Sep-07|

MAY 2021

69

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

70

Tropical countries by region, governance score (Forest Trends 2019), and date of ratification for International
Labour Organization Convention 169 (ILO C169 - Indigenous and Tribal Peoples Convention, 1989 [No. 169])(continued)
Latin America & the Caribbean
Country

Forest Trends
governance score

Haiti
Jamaica

AfricaDate of ratificationof ILO C169

Country

Forest Trends
governance score

88.7

Niger

77.1

39.8

Nigeria

83.2

Réunion

23.7

31.5

Rwanda39.1

Saint Martin (French

Sudan

93.8

Montserrat

Senegal49.3

Somalia99.6Saint Kitts and Nevis
Saint Lucia

Martinique

16.1

Nicaragua

79.7South Sudan

99.0

Panama41.4

Swaziland

67.7

25-Aug-10

Puerto Rico

36.3

Seychelles

35.3

El Salvador

54.0

Chad

93.5

Suriname

60.2

Togo

71.9

Sint Maarten

Tanzania

68.0

Turks and Caicos

Uganda72.6

Trinidad and Tobago

51.4

Zambia67.6

Saint Vincent and

33.9

Zimbabwe

91.7

Venezuela

97.0

British Virgin Islands
Virgin Islands, U.S.

15.6

22-May-02

Date of ratificationof ILO C169APPENDIX 3|

MAY 2021

Appendix 3 Worst-case, best evidence, and best-case estimates ofpercentage of forest loss due to commercial agriculture, illegal
agro-conversion, and agro-conversion linked to exports

Estimates of forest loss due to commercial agriculture, agro-conversion that was likely illegal, and agroconversion that was linked to exports are presented here under a best-case scenario, best-availableevidence scenario, and worst-case scenario. Colors indicate data quality: green represents high quality
data, orange medium quality data and yellow is low quality data.
Forest loss due tocommercial agriculture (%)
VARIABLE B

Agro-conversion thatwas likely illegal (%)
VARIABLE C

Agro-conversion that was
linked to exports (%)
VARIABLE D

Country / Scenario

Best
case

Bestevidence

Worst
case

Best
case

Bestevidence

Worst
case

Best-evidence

Brazil

88%

88%

88%

95%

95%

95%

25%

Argentina

71%

71%

71%

65%

65%

100%

49%

Paraguay

89%

89%

89%

49%

49%

100%

69%

Bolivia

80%

80%

80%

0%

74%

100%

7%

Colombia

84%

84%

84%

89%

89%

89%

4%

Mexico

68%

68%

77%

97%

97%

97%

10%

Peru

66%

66%

66%

51%

51%

100%

11%

Honduras

51%

51%

51%

0%

74%

100%

55%

Indonesia

89%

89%

89%

47%

47%

81%

47%

Malaysia

91%

91%

91%

0%

37%

100%

59%

Myanmar

68%

68%

68%

0%

37%

100%

10%

Cambodia

89%

89%

89%

16%

16%

100%

16%

Vietnam

63%

63%

63%

0%

37%

100%

32%

Laos

56%

56%

56%

49%

49%

100%

20%

Papua New Guinea

30%

30%

30%

63%

63%

100%

99%

Thailand

86%

86%

86%

9%

9%

100%

50%

9%

9%

22%

99%

99%

99%

1%

Democratic Republicof Congo
Angola

2%

2%

2%

0%

71%

100%

0%

Madagascar

3%

3%

3%

100%

100%

100%

1%

Liberia

14%

14%

70%

85%

85%

100%

53%

Sierra Leone

4%

4%

4%

0%

71%

100%

2%

Côte d’Ivoire

62%

62%

62%

26%

26%

100%

64%

Ghana

77%

77%

77%

45%

45%

100%

14%

Rest of the Tropics*
Latin America

15%

15%

15%

74%

74%

98%

17%

Asia

28%

28%

28%

37%

37%

98%

5%

Africa

1%

1%

1%

71%

71%

100%

10%

*For the “rest of the world,” forest loss due to commercial agriculture per country is based on Global Forest Watch data (2020, using
Curtis et al. 2018). Percent illegality is based on the average of the Forest Trends best-available-evidence estimates for high andmedium data-quality countries in the region. Exports are based on Pendrill et al. 2020.

71

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

72

Appendix 4 Tropical forest loss and emissions due to commercial

agriculture, illegal agro-conversion, and export ofproduction linked to agro-conversion
Total Tropical Forest Loss
VARIABLE A

Forest Loss Due to Commercial Agriculture
VARIABLE B

Country

Area lost(in Mha and %)Emissions(MtCO2e)Area lost due
to commercial
agriculture (%)

Area lost due toagro-conversion(Mha)

Emissions(MtCO2e)Brazil20.4 (27%)

12,93188%

18.0

11,3791 (1%)

355

71%

0.7

252

Argentina
Paraguay

1.1 (1%)

354

89%

1.0

315

Bolivia

2.5 (3%)

1,125

80%

2.0

900

Colombia

1.8 (2%)

1,032

84%

1.5

867

Mexico1.6 (2%)

731

68%

1.1

497

Peru

1.5 (2%)

988

66%

1.0

652

Honduras

0.6 (1%)

285

51%

0.3

145

Indonesia

10.6 (14%)

6,843

89%

9.4

6,090

Malaysia

3.3 (4%)

1,774

91%

3.0

1,614

Myanmar

2 (3%)

1,075

68%

1.4

731

Cambodia

0.9 (1%)

567

89%

0.8

505

Vietnam

1.4 (2%)

1,082

63%

0.9

682

Laos

2 (3%)

1,024

56%

1.1

573

Papua New Guinea

0.8 (1%)

612

30%

0.2

184

Thailand

0.9 (1%)

507

86%

0.8

436

DRC

8.1 (11%)

5,275

9%

0.7

475

Angola0.9 (1%)

376

2%

0.0

8

Madagascar

2 (3%)

1,093

3%

0.1

33

Liberia

1.2 (2%)

655

14%

0.2

92

Sierra Leone

1(1%)

485

4%

0.0

19

Côte d’Ivoire

0.9 (1%)

514

62%

0.6

319

Ghana

0.4 (1%)

253

77%

0.3

195

Other LAC

3.4 (4%)

1,976

15%

0.5

296

Other Asia

1.8 (2%)

1,108

28%

0.5

310

Other Africa

4.7 (6%)

2,821

1%

0.0

28

TOTAL

76.9

45,841

60%

46.1

27,597

Data on legality of agro-conversion is categorized by availability and data quality:[1] = high, allowing national estimates of illegality;[2] = medium, good data but not representative of all agro-conversion; and[3] = low, insufficient information to make a reasonable national estimate, even of some sub-sector.
Variable calculations can be found in Appendix 1.

APPENDIX 4

Agro-Conversion Likely to Be Illegal
VARIABLE C
Data quality/
availability on
illegality (1-3)

Agro-conversion
likely illegal (%)|

73

MAY 2021

Agro-Conversion Linked to Exports
VARIABLE D

Minimum area
likely illegal(Mha)

Emissions(MtCO2e)

Production linked
to exports (%)

Area linked toexports (Mha)

Emissions(MtCO2e)

1

95%

17.1

10,810

25%

4.5

2,845

2

65%

0.5

164

49%

0.3

124

2

49%

0.5

154

69%

0.7

217

3

74%

1.5

669

7%

0.1

63

1

89%

1.3

772

4%

0.1

35

1

97%

1.1

482

10%

0.1

50

2

51%

0.5

333

11%

0.1

72

3

74%

0.2

108

55%

0.2

80

2

47%

4.4

2,862

47%

4.4

2,862

3

37%

1.1

594

59%

1.8

952

3

37%

0.5

269

10%

0.1

73

2

16%

0.1

81

16%

0.1

81

3

37%

0.3

251

32%

0.3

218

2

49%

0.5

281

20%

0.2

115

2

63%

0.2

116

99%

0.2

182

2

9%

0.1

39

50%

0.4

218

1

99%

0.7

470

1%

0.0

5

3

71%

0.0

5

0%

0.0

0

1

100%

0.1

33

1%

0.0

0

2

85%

0.1

78

53%

0.1

49

3

71%

0.0

14

2%

0.0

0

2

26%

0.1

83

64%

0.4

204

2

45%

0.2

88

14%

0.0

27

3

74%

0.4

220

17%

0.1

50

3

37%

0.2

114

5%

0.0

16

3

71%

0.0

20

10%

0.0

3

69%

31.7

19,110

31%

14.3

8,540

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

74

Appendix 5 Amount and value of exports in 2019 linked to deforestation
This section outlines the amount and value of exports in 2019 linked to deforestation for the major producer
countries for each of ten key agro-commodities.

Exports (t)VARIABLE F(volume)

Percent
Displacing
Forest
VARIABLE G

Exports
Displacing
Forest (t)VARIABLE F(volume)x
VARIABLE G

Brazil

86,257,817

49%

42,266,330$34,143,807,081$16,730,465,470

95%

Argentina

36,406,078

9%

3,276,547$15,399,779,750$1,385,980,178

65%

Paraguay

6,846,205

57%

3,902,337$2,517,960,954$1,435,237,744

100%

Bolivia

2,096,546

52%

1,090,204$906,761,607$471,516,036

74%

Commodity /Country

Value of Exports(US$)
VARIABLE F(value)Value of Exports
Displacing
Forests (US$)
VARIABLE F(value)x
VARIABLE G

Risk of
Illegality
(%)

SOY

Total

$20,023,199,427

50,535,418

BEEF
Brazil

1,466,721

36%

528,020$6,829,752,742$2,458,710,987

95%

Argentina

696,654

14%

97,532$3,182,591,774$445,562,848

65%

Paraguay

298,19745%

134,189$1,081,656,371$486,745,367

24%

Mexico269,80538%

102,526$1,504,715,721$571,791,974

97%

Total

862,266$3,962,811,176

LEATHER
Brazil

458,024

36%

164,889$1,379,585,563$496,650,803

95%

Argentina

130,30214%

18,242$701,997,552$98,279,657

65%

Paraguay

38,44345%

17,299$68,405,882$30,782,647

24%

Mexico59,37438%

22,562$577,048,923$219,278,591

97%

Total

222,992$844,991,698

COCOA
Ghana

880,68413%

114,489$2,400,471,201$312,061,256

45%

Cote d'Ivoire

2,075,738

40%

830,295$5,539,897,778$2,215,959,111

100%

Total

$2,528,020,367

944,784

PALM OIL
Indonesia

31,949,015

38%

12,140,626$16,235,334,628$6,169,427,159

81%

Malaysia

17,282,965

68%

11,752,416$9,547,187,841$6,492,087,732

37%

84,70044%

37,268$53,917,344$23,723,631

51%

Peru
Total

23,930,310

APPENDIX 5|75

MAY 2021

Exports (t)VARIABLE F(volume)

Percent
Displacing
Forest
VARIABLE G

Exports
Displacing
Forest (t)VARIABLE F(volume)x
VARIABLE G

Indonesia

5,609,279

100%

5,609,279$3,474,161,516$3,474,161,516

68%

Malaysia

41,73914%

5,843$70,665,651$9,893,191

37%

Commodity /Country

Value of Exports(US$)
VARIABLE F(value)Value of Exports
Displacing
Forests (US$)
VARIABLE F(value)x
VARIABLE G

Risk of
Illegality
(%)

PULP

Total

5,615,122$3,484,054,707

PAPER
Indonesia

5,459,420

100%

Total

5,459,420$4,799,339,658

5,459,420$4,799,339,658

68%$4,799,339,658

RUBBER
Cambodia

171,814100%

171,814$204,463,624$204,463,624

16%

Laos

273,10917%

46,429$382,922,271$65,096,786

49%

Vietnam

753,87163%

474,939$1,072,663,372$675,777,924

37%

Malaysia

721,11466%

475,935$1,100,039,911$726,026,341

37%

Indonesia

2,547,109

26%

662,248$4,055,599,339$1,054,455,828

47%

DRC

1,458

15%

219

$1,879,879$281,982

99%

Total

4,468,475

1,831,584$2,726,102,486

COFFEE
Cote d'Ivoire

45,46513%

5,910$73,811,041$9,595,435

26%

Vietnam

1,422,377

15%

213,357$2,456,928,976$368,539,346

37%

Honduras

36895729%

106,998$1,031,639,781$299,175,536

74%

Total

326,265$677,310,318

MAIZE
Argentina

29,335,760

52%

15,254,595.20$6,128,813,587$3,186,983,065

Total

15,254,595.20$3,186,983,065

GRAND TOTAL

104,982,755.93$54,918,051,424

65%

ILLICIT HARVEST, COMPLICIT GOODS:THE STATE OF ILLEGAL DEFORESTATION FOR AGRICULTURE

76 omparison using two different global datasets
Appendix 6 C
This table compares estimates of forest loss for each tropical country using the datasets of Global Forest
Watch (2020) and the FAO Forest Risk Assessment (2020). Both define “forest” and “deforestation” slightly
differently, as discussed in Appendix 1, Box A1.
Global Forest Watch Data

FAO Forest Resources Assessment Data

Area of total
forest loss (Mha)

Calculated percent
of total forest loss
across the tropics

Area of total
forest loss (Mha)

Calculated percent
of total forest loss
across the tropics

Difference

Brazil

20.4

27%

12.4

19%

-8%

Argentina

1.0

1%

1.3

2%

+1%

COUNTRY

Paraguay

1.1

1%

2.4

4%

+3%

Bolivia

2.5

3%

1.6

3%

-

Colombia

1.8

2%

1.2

2%

-

Mexico

1.6

2%

1.3

2%

-

Peru

1.5

2%

1.3

2%

-

Honduras

0.6

1%

0.2

0%

-1%

Indonesia

10.6

14%

5.1

8%

-6%

Malaysia

3.3

4%

0.3

0%

-3%

Myanmar

2.0

3%

2.1

3%

-

Cambodia

0.9

1%

1.7

3%

+2%

Vietnam

1.4

2%

0.1

0%

-2%

Laos

2.0

3%

0.2

0%

-3%

Papua New Guinea

0.8

1%

02

0%

-1%

Thailand

0.9

1%

0.4

1%

-

8.1

11%

7.7

12%

+1%

Democratic Republicof Congo
Angola

0.9

1%

3.9

6%

+5%

Madagascar

2.0

3%

0.1

0%

-3%

Liberia

1.2

2%

0.2

0%

-2%

Sierra Leone

1.0

1%

0.1

0%

-1%

Côte d’Ivoire

0.9

1%

0.8

1%

-

Ghana

0.4

1%

0.0

0%

-1%

3.4

4%

5.8

9%

+5%

1.8

2%

0.3

0%

-2%

4.7

6%

13.7

21%

+15%

69%

-18%

Other Latin American& Caribbean tropicalcountries
Other Asian
tropical countries
Other African
tropical countries
TOTAL

76.9

TOTAL for 23 casestudy countries

67.0

64.2
87%

Source: GFW 2020 (using Hansen et al. 2013); FAO FRA 2020.

44.6

Forest Trends works to conserve forests and other ecosystems through thecreation and wide adoption of a broad range of environmental finance, markets,and other payment and incentive mechanisms. This report was released by Forest
Trends’ Forest Policy, Trade, and Finance program, which seeks to create markets
for legal forest products while supporting parallel transformations away from timberand other commodities sourced illegally and unsustainably from forest areas.
Other policy and information briefs can be found at www.forest-trends.org.

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