The European Union’s consumption of internationally traded commodities exerts a considerable influence on global forest ecosystems. Recognising this impact, the European Union has adopted the EU Deforestation Regulation (EUDR) to promote deforestation-free sustainable and legal value chains. It is directed towards companies that place products, such as cocoa, natural rubber and palm oil on the EU market. They are required to assess and mitigate risks in their value chains.
The global SAFE project (funded by the EU, Germany, and the Netherlands) supports several regional technical dialogues on the EU Deforestation Regulation to improve the understanding of technical details and to build on existing initiatives to eliminate deforestation from value chains. The technical dialogues in Southeast Asia are organised by the Tropical Forest Alliance (TFA) in Indonesia that is hosted by the Indonesia Business Council for Sustainable Development (IBCSD), and partners Solidaridad Malaysia, Cocoa Sustainability Partnership (CSP), and Partnership for Indonesia Sustainable Agriculture (PISAgro). They started the dialogue journey by mapping relevant stakeholders and identified opportunities and challenges by listening and understanding potential barriers on the ground.
Starting with Listening
Starting in March 2024, first Focus Group Discussions brought together actors from the value chains of cocoa, natural rubber, and palm oil as well as governments at different levels to lay out the beginning of the dialogue journey and to identify relevant topics.
What emerged from these focus group discussions in both countries was the perception that smallholder farmers would be facing challenges: ranging from technical barriers related to collecting, registering and verifying data to systemic barriers like limited financial resources and lack of land tenure clarity. While the EUDR places responsibilities on companies regarding collection of information and risk mitigation, stakeholders in Southeast Asia fear that smallholders will be bearing the costs and efforts.
Another finding was that existing data systems were fragmented and not interoperable – neither between national systems, between companies in the country nor with the EU information system. Hence, key recommendations of stakeholders in the events included strengthening inter-agency coordination for better data management, ensuring interoperability of the national standards for palm oil (In Indonesia and Malaysia) with EUDR requirements and enhancing smallholder capacities through targeted training on digital literacy and sustainable agricultural practices.
Stakeholders also called for clearer technical guidance from the EU, financial support and strengthening of cooperatives, while they expected a greater leadership of subnational governments and collaborative models to ensure inclusive participation in deforestation-free supply chains. A shared responsibility model anchored in the “Jurisdictional Approach” calling for public and private collaboration was seen as essential to scale up efforts.
Building Bridges Across Countries
The series of public Regional Technical Dialogues (RTD) started in September 2024, with several cross-country dialogues and jurisdictional dialogues in Indonesia, Malaysia and Papua New Guinea. In Indonesia, discussions concentrated on Smallholder Plantation Registration Certificates (STDB, Surat Tanda Daftar Budidaya) and their transfer to the electronic version. These smallholder registrations are recommended for land areas under 25 hectares of land ownership. They are an important tool that allow farmers to register their land with information on land legality status, geolocation data and the agricultural products cultivated. Yet, obtaining them involves technical challenges when land property is scattered, when water bodies or roads intersect or when land areas overlap.
The discussions further focused on the planned National Dashboard for Commodities – a national platform meant to centralise plantation data in Indonesia. Moreover, both countries emphasised the relevance of their national palm oil certification schemes: Representatives from Malaysia’s Palm Oil Board (MPOB) and Indonesia’s Plantation Fund Management Agency (BPDP) presented the Malaysian Sustainable Palm Oil (MSPO) and The Indonesian Sustainable Palm Oil (ISPO) – stressing their alignment with EUDR requirements.
It is important to emphasise that companies in the value chains can use certification systems as one means to mitigate risks in value chains, however the responsibility will remain with the companies, and it cannot replace the risk assessment.
Discussions revealed that Malaysia’s three complementary palm oil data systems lack full integration and interoperability: GeoSAWIT for mapping, e-MSPO for certification and SIMS for data storage. In contrast, the rubber sector benefits from a more integrated Malaysian Sustainable Natural Rubber (MSNR) system.
Independent smallholders’ reliance on intermediaries such as unlicensed collectors and transporters contributes to data gaps and material mixing, complicating traceability efforts. Geolocation challenges were attributed to outdated records and inconsistent monitoring and Participants expressed concerns regarding data protection, recommended greater safeguards to ensure smallholder inclusion.
Several recommendations were collected regarding land legality: upgrading state-level land registries to issue general agricultural land titles not limited by crop type, issuing provisional land use rights as interim validation pending formal title and formal designation of long-standing agricultural areas to improve legal certainty.
Additional proposals included supporting productivity enhancements to reduce land-use pressure, particularly among smallholders, while strengthening their economic resilience in the supply chain.
From the diverse discussions and interactions, practical solutions emerged, for example: the Global Platform for Sustainable Natural Rubber (GPSNR) across different countries, including Indonesia, presented a model of shared investments where downstream companies collectively fund programs to improve rubber smallholder resilience through replantation of aging trees or promoting agroforestry. Another shared success story was that in the cocoa sector, intermediaries are being strategically empowered for capacity building and transparency initiatives. Furthermore, Vietnam demonstrated how partnerships between farmers, companies, and government can pool resources to finance necessary transitions. Finally, the Philippines illustrated how cooperation between middlemen and local entrepreneurs creates self-sustaining economic loops.
The participants concluded that price premiums and reliable payments are building more long-term partnerships. The regulation is already driving positive changes in terms of governance and fostering greater stakeholder engagement.
The Path Forward
The dialogues surfaced both challenges and opportunities. It was pointed out that national data platforms are evolving, needing strengthening and harmonisation with EUDR requirements. Key take-aways include that many tools were not initially designed with smallholders in mind. Open-source and low-cost solutions are however more and more available for smallholders, such as such as the Ground app for geolocation mapping and Whisp tool for land use analysis, both developed by FAO. These offer pathways for modernised farm and value chain management, strengthened sustainability credentials and access to premium markets.
The Regional Technical Dialogue will continue in the coming months as a space for inclusive engagement and solution-building. Ongoing collaboration around land legality, traceability, and smallholder capacity is critical to support value chain actors across South-East Asia towards a resilient, transparent, and deforestation-free future. A very relevant action will be to strengthen subnational multistakeholder platforms as they are essential in enabling coordination and problem-solving for the inclusion of smallholder farmers.
In the coming months, two more public cross-country dialogue events are planned in Indonesia and Malaysia plus two more dialogues in Papua New Guinea until March 2026.
