Towards a Social Observatory for Monitoring the Implementation of New Supply Chain Regulations

Governments in Europe have increasingly adopted new laws requiring companies to conduct human rights and environmental due diligence. However, the implementation of these laws, particularly the monitoring of risks, has proven to be challenging. Previous research indicates that data on certain issues, such as deforestation, is more well-developed compared to data on human rights impacts, including rights to land, water, and food. Despite the growing recognition of the importance of right-based approaches, where interconnected deforestation and human rights impacts are addressed in an integrated manner, initiatives targeting deforestation have often overlooked the needs and rights of affected local and indigenous communities. Drawing on theories on knowledge in environmental governance and new supply chain regulations, this study focuses on a new initiative to establish a Social Observatory in Brazil. The Social Observation is led by a transnational network of civil society organizations and social scientists, and it seeks to monitor of human rights impacts in the implementation of the EU Deforestation-Free Products Regulation (EUDR). The EUDR aims to reduce the EU's impact on deforestation by prohibiting companies from introducing products tainted with deforestation into the EU market. While the EU has committed to establishing a Forest Observatory for monitoring deforestation, it does not include monitoring of human rights impacts linked to deforestation. Against this backdrop, the Social Observatory aims to ensure that social impacts are not neglected in the implementation and enforcement of the EUDR, thereby contributing to the protection of the rights of vulnerable communities. Drawing on semi-structured interviews, document analysis, and participatory observation at meetings where civil society organizations (CSOs) and scholars developed this initiative, we trace the discussions leading up to the creation of the Social Observatory. Our findings reveal that, despite political will to overcome fragmented approaches, significant challenges persist. These challenges include contestations over the legitimacy of civil society-led databases, difficulties in geolocating and validating data on human rights impacts, addressing knowledge gaps, risks associated with digital data, and ensuring meaningful participation of affected groups in such transnational initiatives. The broader implications of our findings contribute to ongoing debates about the sustainability governance of global supply chains, the policy integration of human rights and the environment, and discussions about how social justice can be upheld in new governance approaches that heavily rely on new forms of digital data.