The proposal will enter into force 12 months after approval.1 What is the scope of the legislation in terms of commodity and ecosystem coverage and treatment of illegality? Under the proposal, relevant commodities and products can only be placed on the EU market or exported from the EU if they are (a) deforestation-free; (b) produced in compliance with the relevant legislation of the producer coun. [...] The proposal includes a review mechanism and the first review (no later than two years after the regulation enters into force) is to include an assessment of the need and feasibility of extending the regulation to other ecosystems and other commodities. [...] This is yet to be defined but is likely to cover a specific list of topics in producer country legislation, for example the right to use the land for the production of the commodity. [...] There are due diligence requirements to provide the geo-localisation coordinates, latitude and longitude of all plots of land where the relevant commodities and products were produced, as well as the date or time range of production, and to assess the risk of mixing of products with those from unknown origin or plots of land where deforestation has occurred. [...] However, many of these concerns assume the need for physically segregated supply chains, which is not explicit in the proposal.3 Civil society has expressed concern about the exclusion of international human rights in the proposal, particularly on land tenure and the rights of indigenous peoples and local communities.
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