Both ENDS, WWF NL, FARN, Fundación Vida Silvestre IUCN NL, Natuur & Milieu, have stressed their opposition to the final FEFAC guidelines in a joint statement:
“We support the effort of FEFAC to align a diversity of feed manufacturing companies in Europe behind a common minimum norm. We appreciate that our comments on the draft were dealt with transparently, and that some of our comments, for example on verification‐in‐the‐field, on aerial spraying of pesticides or waste disposal have been adopted in the final version.
We stress however that we cannot endorse this minimum level as it is now. A major criticism is that FEFAC’s guidelines are allowing legal deforestation and conversion of other valuable habitats.”
FEFAC holds that the guidelines, released in August and backed by the EU vegetable oil and protein meal industry (FEDIOL) in consultation with stakeholders in soy growing countries, are “a set of baseline criteria” developed to realize a physical transition of soy produced according to those parameters to Europe.
The EU feed trade group said its objective is to establish a base level in the market and raise that baseline over time.
Tamara Mohr of Both ENDS, hosting the secretariat of the Dutch Soy Coalition, said soy production based on the parameters in the FEFAC guidelines should not be confused with ‘responsible’ soy.
She told FeedNavigator the FEFAC guidelines “could be presented as a step in the direction of responsibility when accompanied by a time bound plan on how soy being sourced by Europe, through continuous improvement, could reach the level of roundtable for responsible soy (RTRS) or equivalent.”
She said one positive aspect of the FEFAC initiative is that it might motivate European stakeholders that, so far, have not shown interest in any form of certified soy to gain interest in this issue.
“But some crucial issues are not included in the final [FEFAC guidelines] criteria.They are lower [in terms of minimum social and environmental requirements for soy expansion and cultivation] than the RTRS, which are considered minimum criteria already. In practice, in relation to the deforestation issue, which started the whole discussion on responsible soy, FEFAC will only cover legality. This can by no means be considered responsible nor sustainable, and FEFAC should not mislead the sector by communicating as if it were,” said Mohr.
Joint NGO statement
The NGOs also said, despite their comments in the consultation phase on the draft guidelines, there has been no change in criteria 28: ‘no soy is produced on land that was illegally deforested after a certain cut‐off date mentioned in national legislation such as 2008 in Brazil, 2008 in the US."
The organizations said they had indicated that parameter should refer to an ‘internationally’ defined cut-off date after which no deforestation is allowed due to the fact that not all countries and regions have sufficient legislations in place.
The group also requested the FEFAC guidelines should go beyond illegal deforestation: “In the drier, vulnerable areas that have a low protection status such as the Gran Chaco — Argentina, Bolivia, Paraguay — or the Brazilian Cerrado, actual — illegal and legal — expansion of soy far exceeds responsible levels.”
The joint statement from the NGOs continued: “We urge FEFAC to formulate clear ambitions and timelines to make explicit when all soy imported by FEFAC members should be produced according to their guidelines, and by when FEFAC members should be sourcing RTRS‐certified or equivalent responsible soy.
In this process, monitoring volumes and transparently communicating progress towards these goals are key. Without an explicit ambition to create volume, and push up the bar to a responsible level, the guidelines will not be a ‘game changer’."
Deforestation
On the release of the draft guidelines back in April, a spokesperson for the ProTerra Foundation, a non-profit group that supports the sourcing of sustainably produced, non-GM crops for feed and food, told FeedNavigator it backed the FEFAC approach and the work that had been achieved “after ten years’ of discussion.”
However, the spokesperson noted one weak point was that the guidelines did not endorse the zero net deforestation target – a firm objective for ProTerra and the RTRS.
“We support the principle of zero net deforestation as demanding zero deforestation per definition is an unrealistic target but zero net requires synergetic efforts from both the private and public sectors – it needs the involvement of national authorities.
As it stands, our guidelines are in line with the revised Brazilian Forest Code, which together with the federal monitoring of farms under the rural environmental registration (CAR), we see as a real breakthrough in terms of enabling responsible soy production,” said Ruud Tijssens, president of FEFAC, in reaction to her remarks then.
Sandra Mulder, senior advisor on soy markets from WWF Netherlands, said that with regard to forest destruction, the FEFAC guidelines are aimed at stopping illegal deforestation. However, many forests and natural habitats are not protected by law.
"Though FEFAC is suggesting it will, in due time, raise the level of its guidelines, this will be too late for many of the forests. A ‘no deforestation’ pledge cannot be implemented stepwise, as forest that is converted into agricultural land can never be restored to its original status,” she added.
Background to guidelines
In April, Tijssens told us about the background to the development of the FEFAC soy sourcing guidelines:
“In certain markets the topic of responsible soy farming is very high on the agenda as in North-Western Europe, and the debate tends to be led by downstream players in the chain such as retailers or dairy companies. In markets in Southern and South-Eastern Europe that debate is virtually non-existent, while stakeholders in other markets tend to weigh in more on the non-GMO supply.
Moreover, the definition of responsible soy production varies from market to market – for some it is about ensuring no deforestation in the Amazon, for others it is about good agricultural practices and crop protection methods.
In order to ensure that soy supply to Europe would not be undermined by this lack of coherence and potentially diverse production stipulations in regards to what exactly constitutes responsible soy production, FEFAC recognized it had to step in and generate some homogeneity on this topic.”