Globally traded commodities that can be grown in forest-like agricultural systems —known as agroforestry— have long been part of the solution for stabilizing forest margins. These systems enable local communities to use land effectively while avoiding the ecological risks associated with open-field agriculture. Now, however, this approach finds itself at odds with new efforts to protect forests, as counterintuitive as this may sound. While well-intentioned initiatives aim to advance ‘deforestation–free’ trade and shield forests from greedy hands, the effectiveness of such policies depends heavily on how ‘forest’ is defined. From the vantage point of a satellite, forest-like forms of agriculture, such as agroforestry (AF), are easily mistaken for natural forest—an error that could carry unintended consequences.
The European Union Deforestation-free trade Regulation (EUDR), which will be fully enforced by December 2025 for large enterprises and by June 2026 for small and medium-sized enterprises, aims to ensure that EU customers are no longer part of the drivers of ongoing deforestation linked to agricultural commodity exports. The EUDR follows a long tradition of efforts to control, reduce, manage or eliminate deforestation – but has its design sufficiently accounted for why previous efforts and commitments only partially delivered on their promises?
Researchers at the Center for International Forestry Research and World Agroforestry (CIFOR-ICRAF) have joined ‘the EUDR debate’. One side emphasizes the urgency of action; the other the need to avoid common pitfalls of oversimplified (‘silver bullet’) solutions, minimize collateral damage and give substance to the common but differentiated responsibility (‘CBDR’) for addressing development deficits within the safe space defined by planetary boundaries.
The urgency of protecting the world’s remaining old-growth natural forests is well established through many international agreements addressing climate change and biodiversity loss. Much of the land from which forests are cleared—or made vulnerable to spreading fires—after a varying period, is eventually used for agriculture. The drivers vary by context, but both local food production and export-oriented commodities share the role of main driver, depending on the local context. The EU’s role as an importer of deforestation-based products depends on the commodity and the location of origin, but is substantial for at least some cases.
“Common pitfalls that have been recognized in the EUDR include oversimplification of the complex and diverse realities on the ground into a single ‘forest-vs-non-forest’ dichotomy,” says Meine van Noordwijk, CIFOR-ICRAF Distinguished Science Fellow and lead author of the recent publication. “There is also overconfidence in a single technical solution: location-based assessment of ‘deforestation’. While there have been efforts to correct the initial oversight of social impacts on smallholders at forest margins, these have come ‘rather late’ and remain ‘insufficient’. The limited synergy with the Sustainable Development Goals (SDGs) and its lack of integration into exporting countries’ frameworks contributes to a sense of ‘overreach’ and ‘overkill’—especially when any tree in a functional landscape is treated as equivalent to a forest of global conservation value.”
Maps developed by EU agencies to support EUDR implementation claimed that the world had 12% more forest in 2020 than indicated by other sources. Validation studies show that there is an 18% chance that a spatial unit marked as forest in one dataset is considered non-forest in another.
“As far as we can judge, a substantial part of the discrepancy is tree cover used in agroforestry,” says Peter Minang, CIFOR-ICRAF’s Africa Director and co-author of the publication. “Map errors have two major consequences: (1) Deforestation-based products may still reach European markets; and (2) traders may avoid EUDR-compliant products if they think these will be flagged as risky and rejected at the border. The second consequence is already harming agroforesters, as we’re hearing from people on the ground in many countries. It’s collateral damage—a strong term, but unfortunately accurate.”
“We found that for agroforestry gardens in Indonesia producing coffee, cocoa or rubber, there is a 63% probability that they are (erroneously) mapped as forest in recent datasets,” says Sonya Dewi, CIFOR-ICRAF’s Asia Director and co-author. “Agroforestry typically combines planted, naturally regenerated, or retained trees from previous land uses, often without rigid spatial patterns. It takes familiarity with the local context to distinguish these systems from natural forests in satellite imagery.”
Recent official EU communications on the EUDR have downplayed concerns over the reliability of the forest map prepared by the EU Joint Research Centre (JRC) for determining the cut-off date for EUDR compliance. But that raises a deeper question: Did the EU-JRC fail in execution, or were they asked to map something that cannot be accurately mapped under current assumptions?
“With further collaborative efforts, map uncertainties can be reduced, but country-specific forest definitions must be recognized in global climate change policies,” says Beria Leimona, who leads CIFOR-ICRAF’s climate research and also co-authored the publications. “The EUDR would face less resistance if it were more smoothly integrated into jurisdictional-level action plans—especially those that clearly acknowledge the role of agricultural tree cover outside of forests.”
Further reading
Beyond imperfect maps: evidence for EUDR-compliant agroforestry. June 2025. People and Nature. DOI:10.1002/pan3.70088(forthcoming) Blog: https://relationalthinkingblog.com
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