An actor-centered analysis of the EU Deforestation Regulation and implications for legal and sustainable forest-risk commodity supply chains

The EU has recently adopted a new Deforestation Regulation (EUDR) to close regulatory gaps in not regulating the sustainability and legality of transnational forest and agricultural commodity supply chains. The EUDR will repeal the EU Timber Regulation and significantly reduce the role of FLEGT Voluntary Partnership Agreements and private regulation (i.e., certification). We analyze this EU external action-oriented trade policy change by drawing on two actor-centered regulatory policy change theories, the Advocacy Coalition Framework and Multi-Level Governance Model. To address knowledge gaps concerning the degree of consensus needed to institute policy changes in the EU’s multi-level policy-making system, we qualitatively analyze the institutionalization of policy core beliefs and interests of key state and non-state actors in the EUDR. Our results show that the EUDR’s final legislative text is a compromise solution between the European Parliament’s and Council of the European Union’s more extreme positions, institutionalizing core beliefs and interests of pro- and contra-regulatory state and non-state actors. Pro-change actors (e.g., European Parliament, ENGOs, Amsterdam Declaration Partnership) were more powerful in translating their respective beliefs and interests compared to contra-regulatory agents of status-quo or stability (e.g., import-dependent EU domestic businesses, forest-rich EU Member States, export-dependent governmental authorities and businesses from tropical producer countries) into the new EU trade rules. We assess potential implications for regulatory effectiveness, as in regulatory acceptance, compliance, implementation, enforcement, and on-the-ground impacts in terms of reducing global deforestation and forest degradation.