An aerial view of the Indonesia Weda Bay Industrial Park (IWIP), including captive coal plants and nickel smelting operations. Credit: Muhammad Fadli for CRI.
Despite significant reductions in deforestation under President Luiz Inácio Lula da Silva, forest loss in Brazil remains dangerously high, particularly in the Amazon, where cattle ranching continues to be the single largest driver of deforestation. Scientists warn that continued forest destruction could push the Amazon toward a tipping point, with profound consequences for global efforts to address climate change. In many parts of Brazil, this cattle-driven deforestation is fueled by serious human rights abuses, including forced labor and invasions of Indigenous lands. These abuses are not incidental to forest destruction: by keeping labor costs artificially low or usurping Indigenous lands, ranchers engaged in illegal deforestation increase the likelihood that their environmental crimes translate into financial gain.
Brazil’s ability to reverse this trajectory remains constrained by the powerful economic incentives—including access to lucrative international markets—that continue to reward cattle production on illegally cleared lands. One of the surest ways to alter this economic equation is to prevent products linked to deforestation and related human rights abuses from reaching those markets—which, in turn, requires supply chains that can be traced to their source and screened for links to deforestation, forced labor, and other serious abuses.
The European Union (EU) has adopted several supply chain laws that have the potential to help shift these economic incentives and reinforce Brazil’s own legal framework and policy efforts to curb cattle-driven deforestation, forced labor, and other related abuses. These laws will fundamentally change the obligations of companies placing cattle products on the European market. The most significant are:
These laws will begin to take effect from 2026 onward. The EUDR is set to apply at the end of 2026, the FLR will fully apply from December 2027, and the CSDDD from July 2029. While their application is staggered, companies placing cattle products on the EU market will, in practice, need to prepare now to meet their cumulative requirements.
Taken together, these prohibitions and due diligence requirements mean that companies placing beef, leather, and other cattle products on the EU market will need to ensure that their supply chains can be traced, that products are not linked to deforestation, forced labor, or other serious environmental or human rights violations, and that compliance can be demonstrated with credible documentation. The EUDR and the FLR apply to products placed on the EU market regardless of where they were produced, while the CSDDD requires large companies to conduct due diligence across their global value chains.
Although leather products manufactured outside the EU are not covered by the EUDR—and leather hides would also be excluded under a Delegated Act adopted by the European Commission, if it enters into force following scrutiny by the European Parliament and the Council of the EU—companies importing leather and leather products will still be subject to the FLR and the CSDDD. Consequently, they will need to be able to trace supply chains, identify and mitigate risks linked to forced labor and other serious abuses, maintain credible documentation, and, under the CSDDD, address human rights and certain environmental harms.
For companies importing into the EU cattle products that originate in Brazil—or that contain cattle inputs such as leather originating in Brazil—meeting EU legal requirements will present significant challenges. As Climate Rights International documented in our 2025 report, “Before It’s Too Late,” Brazil’s cattle sector is associated with widespread deforestation, forced labor, and other abuses. At the same time, cattle frequently pass through multiple farms before reaching slaughterhouses and tanneries, meaning that for every direct supplier, companies often have multiple indirect suppliers. Under current conditions, large portions of these upstream supply chains are difficult to trace.
As a result of this indirect supplier problem, and the prevalence of deforestation and human rights abuses in the Brazil cattle industry, companies that source beef or leather from Brazil will face serious obstacles in meeting EU requirements. Where they cannot, they will risk significant regulatory and financial consequences, including loss of access to the EU market, administrative penalties, exposure to civil liability, and damage to business relationships and public reputation.
To address the indirect supplier problem, companies will need to incorporate credible traceability and monitoring mechanisms into their due diligence procedures. They should begin by prioritizing sourcing from supply chains in Brazilian states with credible mechanisms that screen indirect suppliers for links to deforestation. Companies should also adopt sourcing policies that encourage broader screening—including for forced labor, invasions of Indigenous lands, and other human rights abuses—by the mechanisms already operating in some states, their adoption by additional states, and ultimately the development of a transparent national system. Together, these steps would strengthen companies’ ability to comply with the new EU laws while reinforcing market incentives that support Brazil’s efforts to curb deforestation and related human rights abuses.
The five elements below describe what full compliance with the EUDR, FLR, and CSDDD will entail in practice. These requirements—analyzed in detail in the accompanying annexes—set demanding benchmarks against which companies’ systems and supply chains will be assessed.
Companies will need to be able to identify every farm where the cattle used in their products were raised: not only the final “fattening” farm that sells animals to the slaughterhouse, but also every earlier farm where the animals spent time. They will also need to be able to identify precise farm locations to allow verification through satellite monitoring and official databases in line with EU requirements.
Companies will need to ensure that supplying farms are not on land subject to recent deforestation, whether legal or illegal, and that cattle production complied with applicable environmental and other relevant laws.
Companies will need to ensure that the products they place on the EU market are not made with forced labor or linked to other serious human rights abuses at any stage of the supply chain, from birth farms to slaughterhouses and tanneries.
The absence of documented evidence of environmental harms or human rights abuses in a company’s supply chain does not, by itself, establish compliance with EU requirements. Companies will also need to show that they have taken appropriate steps to identify and address such risks—for example, by seeking additional information, conducting checks or audits on suppliers, and, where necessary, excluding high-risk sources. Compliance will therefore extend both to the prevention of harms and to the integrity of the due diligence process.
Companies will need to maintain records showing how they traced their supply chains, verified farm locations, assessed risks of deforestation, forced labor, and other abuses, and addressed those risks when identified. EU authorities will need to be able to review this documentation during compliance checks or investigations.
In sum, to demonstrate compliance with the new EU regulatory framework (EUDR, FLR, and CSDDD), companies with links to cattle supply chains in Brazil will need to be able to answer several basic questions:
Under current conditions in Brazil’s cattle sector, companies sourcing Brazilian beef or leather will face serious obstacles in answering these questions—and meeting EU requirements.
As Climate Rights International documented in “Before It’s Too Late,” Brazil’s cattle sector is characterized by persistent links to illegal deforestation, forced labor, and invasions of Indigenous lands, while major gaps in cattle traceability mean that large numbers of indirect suppliers remain outside existing monitoring systems. That report provides a detailed factual record of these problems, including victim testimony, interviews with experts and government officials, and supply-chain tracing linking cattle and leather associated with illegal deforestation, forced labor, and invasions of Indigenous lands to major Brazilian exporters and global brands.
Cattle ranching is the largest driver of deforestation in Brazil, particularly in the Amazon. Forests are cleared to create pasture for cattle, often in violation of domestic environmental laws.
In many parts of the country, this cattle-driven deforestation is fueled by serious human rights abuses—including forced labor and invasions of Indigenous lands. These abuses are not incidental to Brazil’s forest destruction: by keeping labor costs artificially low or usurping Indigenous lands, ranchers engaged in illegal deforestation increase the likelihood that their environmental crimes translate into financial gain.
Ranchers clearing Brazil’s forests frequently use forced labor and other forms of severe labor exploitation—referred to in Brazilian law as “conditions analogous to slavery.” Workers are brought to remote areas through misleading recruitment practices and then subjected to harsh and often dangerous conditions, with limited ability to leave due to coercion, threats, or isolation. Since 1995, federal labor inspectors have rescued more than 17,000 people from such conditions on cattle farms, demonstrating the persistence and scale of the problem.
Cattle-driven deforestation also entails incursions into Indigenous territories, violating the rights of Indigenous peoples and targeting lands that have long been subject to illegal clearing and cattle production. As of 2020, invaders had sought to lay claim to more than 120,000 square kilometers of Indigenous lands across Brazil—an area nearly three times the size of Switzerland.
Reviews by civil society organizations and journalists have identified large numbers of cases over the past decade linking the supply chains of major Brazilian exporters of beef and leather to cattle producers implicated in illegal deforestation and human rights abuses. For companies operating in or exporting to the EU, these patterns are not isolated incidents but indicators of systemic risk that regulators and, increasingly, litigants, are prepared to examine.
Cattle often pass through multiple farms before reaching slaughterhouses, a process that can obscure their origin and allow producers to conceal links to illegal deforestation or other abuses. For every direct supplier, slaughterhouses often have multiple indirect suppliers—and large numbers of these indirect suppliers remain unmonitored. As a result, even a slaughterhouse that buys only from apparently “clean” farms cannot guarantee that those animals were not raised, at least in part, on farms linked to deforestation or abuse.
While some meatpackers and tanneries have taken steps to monitor their supply chains, these measures typically have limited capacity to vet indirect suppliers. Several beef and leather exporters have announced plans to develop new tracing systems to address this gap. However, their ability to identify indirect suppliers depends on their access to information about cattle movements that have only been made public—earlier this year—in one state, Pará. In all other states, they must rely on producers throughout the supply chain to voluntarily provide complete information about cattle movements—something experts on Brazil’s cattle sector consider highly unlikely.
As a result, even where companies themselves take steps to improve the monitoring of their supply chains, they are unlikely to obtain the information needed to identify their indirect suppliers in most states or assemble the evidence required to fully meet EU requirements. Addressing this gap requires access to complete tracing data that—outside of Pará state—only government authorities have.
Where companies cannot demonstrate compliance with these requirements, EU authorities may impose a range of enforcement measures, including market exclusion, financial penalties, and other sanctions. These enforcement powers may be complemented by litigation, meaning that exposure may be both regulatory and judicial.
Under the EUDR, where companies cannot demonstrate that a product is deforestation-free, lawfully produced, and traceable to its relevant plots of origin, authorities may, among other things:
Under the FLR, if authorities determine that forced labor contributed to a product at any stage of production, they may, among other things:
Under the CSDDD, for companies within the scope of the Directive, supervisory authorities may, among other things:
Across the three instruments, non-compliance may result in market exclusion (EUDR, FLR), corrective due diligence orders (CSDDD), and financial penalties (all three laws), depending on the nature of the breach.
Beyond these regulatory consequences, non-compliance may also give rise to civil liability, including through litigation. First, some of the regulatory scrutiny and the evidentiary record developed under each of the three EU laws can lead to increased corporate civil liability. Second, both the EUDR and the CSDDD create new legally binding standards of corporate conduct, such as the duty to identify the geolocation of farms and the duty to identify and address the risks that are the most severe and most likely. Breaches to these due diligence obligations may lead, in turn, to an increase in civil claims against EU operators before domestic courts.
The same conduct may also be characterized as a crime in a number of European jurisdictions under national laws implementing the EU Directive on the Protection of the Environment through Criminal Law (the “Environmental Crime Directive” or ECD). The ECD creates a further and distinct layer of legal exposure for companies and their executives, particularly in relation to serious cases of unlawful deforestation and other environmental harms. In such cases, the evidentiary record developed through regulatory enforcement may help establish that unlawful conduct occurred, clarify what companies knew or should have known, and show how commercial activities were connected to those practices. While the existence of such evidence does not automatically trigger criminal liability, it may help establish the factual bases for criminal proceedings.
The Directive, which entered into force on May 20, 2024, represents a substantial escalation in the legal consequences that can flow from serious environmental harm. It requires member states to impose criminal, not merely administrative or civil, liability on both companies and individuals, including managing directors and board members.
The ECD contains twenty defined criminal offences, including the placing on the market of relevant commodities and products in breach of the EUDR. Most significantly for companies operating in the cattle sector, the Directive introduces offences “comparable to ecocide,” a category covering particularly widespread or long-term environmental damage caused by conduct that is either intentional or negligent.
The criminal liability threshold under the ECD is lower than many executives may assume. For some offences, criminal liability may arise not only from intentional conduct but also from conduct carried out with at least serious negligence. Individuals, including company directors and board members, can face prison sentences of up to eight years for environmental crimes, rising to ten years where the offence results in death. Companies can face fines reaching 5% of their total worldwide annual turnover, or amounts corresponding to at least €40 million for the most serious offences. Member States may impose higher penalties. Additional sanctions available to courts include temporary or permanent exclusion from public procurement and temporary prohibition from carrying out commercial activities.
For companies and their executives with supply chains linked to serious and widespread deforestation or related environmental harm in Brazil, the ECD materially raises the stakes of non-compliance. Conduct that gives rise to administrative penalties or civil claims under the EUDR, FLR, or CSDDD may also give rise to criminal liability under national laws implementing the Directive. The evidentiary record developed under the EUDR, CSDDD, and FLR, including findings from regulatory enforcement, civil society investigations, and supply-chain audits, may serve as the evidentiary foundation for criminal proceedings as well.
Civil society actors can play a critical role in how EU rules on deforestation, forced labor, and due diligence are applied in practice. They can trigger regulatory scrutiny, shape the evidentiary record, and help ensure that authorities act on reliable information indicating possible non-compliance. Taken together, the complaint, review, and participation mechanisms built into these regimes, coupled with the sustained engagement of civil society actors, create a strong expectation that these laws will be implemented rigorously in practice, particularly where reliable and verifiable evidence of non-compliance is brought forward.
Information generated by civil society actors—whether submitted to authorities or made public through reports and advocacy—can trigger scrutiny across all three regimes at once: it may raise questions about deforestation, legality, and traceability under the EUDR; about forced labor at any stage of production under the FLR; and about whether the company has adequately identified, prevented, mitigated, monitored, and remediated risks under the CSDDD.
Importantly, across these regimes, the evidentiary threshold for initiating action is low: information brought forward by civil society actors does not need to establish a complete case, but must be sufficient to indicate possible non-compliance to prompt further assessment by authorities.
At the same time, civil society actors can also help build a more detailed evidentiary record that, in turn, supports regulators’ conclusions that companies have failed to comply with EU requirements. They can assemble and bring forward evidence drawn from multiple sources—satellite monitoring, supply-chain data, labor inspections, land registries, and on-the-ground testimony—to test whether companies can demonstrate the origin of their products, the legality of production, whether products were made with forced labor, and the effectiveness of their due diligence systems.
The EU regulatory framework described in this memo sits within a broader and rapidly developing international legal context. In 2025, two landmark advisory opinions from international courts clarified and strengthened the legal obligations of states in relation to the climate crisis and its links to human rights, climate and environmental harm. These opinions do not create binding law in themselves, but the host of international laws that they interpret are indeed binding, and the opinions carry significant legal authority, helping to crystallize emerging standards of customary international law.
On July 3, 2025, the Inter-American Court of Human Rights (IACtHR) issued its Advisory Opinion on the Climate Emergency and Human Rights. The Court held that the climate emergency gives rise to a heightened standard of “reinforced due diligence” and emphasized that states must regulate private actors whose activities contribute to climate-related human rights harms. Among other measures, states should require human rights and environmental due diligence, strengthen due diligence and transparency obligations, adopt measures to prevent and address corporate impacts on human rights and the environment, and combat greenwashing and undue corporate influence over public decision-making.
On July 23, 2025, the International Court of Justice (ICJ) delivered its Advisory Opinion on the Obligations of States in Respect of Climate Change. The Court confirmed that states have binding obligations under international law to exercise due diligence in preventing significant climate-related harm, including by regulating the conduct of private actors within their jurisdiction or control. The Court emphasized that states must adopt and enforce legislative and regulatory measures addressing private-sector climate-related harms, taking into account evolving scientific knowledge and the need for effective implementation and enforcement.
Together, these advisory opinions reinforce the regulatory approaches reflected in the EUDR, FLR, CSDDD, and ECD. Both courts emphasized that states’ obligations to address climate change extend beyond direct state action and include the adoption of legal and regulatory frameworks governing corporate conduct, particularly through due diligence, transparency, disclosure, and other measures aimed at preventing environmental and human rights harms throughout corporate value chains.
For companies that import cattle products from Brazil to the EU, reducing risk and strengthening compliance with the new EU laws will require action on multiple fronts—including pressing suppliers to strengthen their own due diligence systems. Yet, in one critical area—tracing indirect suppliers across the supply chain—companies currently have limited capacity to meet their obligations acting alone. As a result, they will need to have alternative approaches to reduce risk and demonstrate compliance.
Brazil has developed tools that can make this possible. These include the Animal Transit Guide (GTA), which enables tracing of full supply chains, as well as separate data tools to monitor whether individual farms comply with key laws protecting the environment, workers, and Indigenous communities. Historically, however, GTA data has not been publicly accessible, meaning that only government authorities could combine cattle-movement records with compliance-monitoring information to assess risks linked to indirect suppliers.
Some states have begun to do exactly that through official traceability and monitoring mechanisms. By integrating non-public GTA records with compliance-monitoring databases, these mechanisms can allow companies to identify whether prospective suppliers are linked through upstream suppliers to environmental or human rights harms, without providing companies or the general public with direct access to the underlying GTA records or the identities of indirect suppliers. Where the mechanisms identify such links in a supplier’s upstream supply chain, companies can exclude the direct supplier—and thereby avoid sourcing from the non-compliant upstream supply chain—or press the direct supplier to strengthen its own sourcing practices.
Two states, Minas Gerais and Pará, currently operate such mechanisms, and several others are developing them. At present, these mechanisms screen indirect suppliers only for deforestation, but they could be expanded to incorporate monitoring for forced labor, invasions of Indigenous lands, and other serious abuses.
In addition, a new path forward has emerged in Pará state, where a court ruling issued in October 2025 made GTA data publicly accessible for the first time (Ação Civil Pública nº 1013342-35.2020.4.01.3900). If the decision is effectively implemented, companies and other actors, including civil society organizations and researchers, will be able to conduct their own tracing and monitoring of upstream supply chains in Pará without relying on government authorities to combine the datasets for them. If other states were to make GTA data publicly accessible, it would allow them to conduct their own tracing and monitoring in those jurisdictions as well.
Yet even in states where GTA data becomes publicly available, government-backed traceability and monitoring mechanisms will have a critical role to play. These mechanisms will be able to apply standardized, government-backed risk classifications that individual companies would struggle to replicate consistently on their own. They will also enable meaningful outside scrutiny: civil society groups, journalists, and smaller companies generally will not have the capacity on their own to conduct complex supply-chain tracing across thousands of cattle movements—nor the resources to pay third parties to do so for them—but they can use the outputs of free state mechanisms to assess whether the companies’ claims regarding their supply chains are accurate.
At the same time, to be fully effective, these government-backed mechanisms will themselves require meaningful oversight by civil society and other stakeholders. Ideally, they should be operated by independent entities and governed by committees that include civil society organizations, academic experts, and industry representatives—and, where possible, they should operate in coordination with the Federal Prosecutor’s Office and relevant government agencies responsible for enforcing relevant Brazilian laws. Without such oversight, the credibility of these mechanisms—and the risk classifications they produce—cannot be assured.
The use of these traceability and monitoring mechanisms will not, by itself, allow companies to ensure full compliance with the requirements of the new EU supply chain laws outlined above. However, without the use of these mechanisms, companies will have significant difficulty identifying indirect suppliers linked to some of the most egregious adverse impacts already documented by Brazilian authorities.
In order to reduce the risk of non-compliance with the new EU laws—and the likelihood of contributing to cattle-driven deforestation, forced labor, and other serious human rights abuses—companies sourcing cattle products from Brazil will need to strengthen due diligence across their entire supply chain, and press their suppliers to do the same. And when it comes to the critical problem of identifying and addressing risks associated with indirect suppliers, they should take the following complementary steps, using the commercial leverage created by the new EU laws to encourage and support ongoing efforts in Brazil to establish and strengthen public traceability and monitoring mechanisms.
Taken together, these recommendations are not a complete solution to the risk of contributing to cattle-driven deforestation, forced labor, and other serious human rights abuses. But they can strengthen companies’ ability to comply with the new EU laws in the short term while helping lay the foundation for the transparent national traceability and monitoring mechanism that Brazil ultimately needs.
The European Union Deforestation Regulation (EUDR) establishes a binding market access regime aimed at eliminating deforestation and forest degradation from European Union (EU) supply chains by conditioning the placing of certain commodities and derived products on the EU market, as well as their export, on compliance with specified environmental and legal requirements.1See EUDR (2025 consolidated version), Article 1(1), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R1115-20251226.
The Regulation reflects the EU’s determination that consumption within the Union contributes to global deforestation, greenhouse gas emissions, and biodiversity loss, and that trade measures are necessary to reduce that contribution.2See EUDR (2025 consolidated version), Article 1(1)(a) and (b).
The EUDR applies to a defined set of commodities and derived products and extends to both imports and goods produced within the EU.3See EUDR (2025 consolidated version), Article 1(1) and Annex I.
The Regulation combines two interrelated elements. It establishes a product-based prohibition: commodities and products may not be placed on the EU market or exported unless they are deforestation-free, produced in accordance with applicable laws, and covered by a due diligence statement.4See EUDR (2025 consolidated version), Article 3. It also imposes a due diligence obligation: operators must collect information, assess risk, and adopt mitigation measures sufficient to demonstrate compliance with those conditions.5See EUDR (2025 consolidated version), Articles 8–11. In sum, compliance depends both on the characteristics of the product and on the adequacy of the due diligence system supporting it.
While the Regulation establishes a strict legal standard, in practice compliance is assessed through a risk-based enforcement framework. Authorities evaluate whether operators can demonstrate, on the basis of sufficiently reliable and verifiable information, that the risk of non-compliance is no more than negligible.
Commodities and Products Covered
The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood.6See EUDR (2025 consolidated version), Article 2(1).It also applies to a range of derived products associated with those commodities, including, for example, beef and processed meat products (from cattle), chocolate (from cocoa), and furniture and paper (from wood).7See EUDR (2025 consolidated version), Annex I (listing relevant commodities and products under Combined Nomenclature codes).
For cattle, the scope includes live animals, fresh and frozen beef, edible offal, and processed meat products.8See EUDR (2025 consolidated version), Annex I, Section “Cattle.” It may no longer include hides, following the European Commission’s adoption of a Delegated Regulation on 13 July 2026 proposing their exclusion, nor does it extend to finished leather goods such as footwear or other manufactured articles.9On July 13, 2026, the European Commission adopted a Delegated Act proposing the removal of hides and skins from Annex I of the EUDR (European Commission, Commission Delegated Regulation (EU) …/… of 13 July 2026 amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products, C(2026) 4920 final). The Act remains under review by the EU Parliament and the EU Council. Even if the Act enters into force, however, leather products and hides placed on the EU market would remain subject to other EU measures, including the Forced Labour Regulation and, for companies within its scope, the Corporate Sustainability Due Diligence Directive.
Operators Covered
The Regulation applies to operators, downstream operators, and traders engaged in the placing, making available, or export of relevant products in the course of commercial activity.10See EUDR (2025 consolidated version), Articles 2(15), 2(15b), and 5.
Smaller companies are subject to lighter administrative requirements, but all operators—including large importers—must meet the same substantive conditions for placing products on the EU market.11See EUDR (2025 consolidated version), Articles 4, 4a, and 5.
Entry Into Force and Application
The EUDR entered into force 20 days after its publication in June 2023.12See EUDR (2025 consolidated version), Article 38(1). Following amendments adopted in December 2025, the application of its substantive obligations has been postponed to December 30, 2026.13See EUDR (2025 consolidated version), Article 38(2), as amended.For micro and small operators established as such by December 31, 2024, application is further deferred to June 30, 2027.14See EUDR (2025 consolidated version), Article 38(3), as amended.
The EUDR conditions access to the EU market on three requirements set out in Article 3: relevant products must be deforestation-free; produced in accordance with the relevant legislation of the country of production; and covered by a due diligence statement. Articles 8 to 12 clarify that compliance with these conditions must be demonstrated through a due diligence process requiring operators to collect and assess information and, where necessary, take measures to address identified risks.
Compliance is therefore both an obligation of results (the product must meet the applicable conditions) and an obligation of means (the operator must demonstrate, through a due diligence process, that it does).15See EUDR (2025 consolidated version), Article 3 (setting out the conditions for placing products on the EU market), together with Articles 8–11 (establishing due diligence obligations including information collection, risk assessment, and mitigation). Taken together, these requirements mean operators must be able to substantiate, on the basis of adequately conclusive and verifiable information, that their products and due diligence processes meet the Regulation’s conditions.
(1) That the Products are Deforestation-Free
Relevant products may not be placed on the EU market unless they derive from commodities produced on land not subject to deforestation after December 31, 2020, regardless of whether that deforestation was legal under domestic law.16See EUDR (2025 consolidated version), Article 3(a), read together with Article 2(13).
(2) That the Products Were Produced in Accordance with the Relevant Legislation of the Country of Production
Products covered by the Regulation may not be placed on the EU market unless they are produced in compliance with the “relevant legislation of the country of production.”17See EUDR (2025 consolidated version), Article 3(b), read together with Article 2(40).
“Relevant legislation” includes laws relating to land use rights, environmental protection, forest management, biodiversity conservation, labor rights, human rights, Indigenous rights, and other applicable legal frameworks, insofar as they are relevant within the meaning of the Regulation.18See EUDR (2025 consolidated version), Article 2(40). This requirement focuses on whether production at a given location is lawful. Compliance must therefore be assessed at the level of the specific plots of land or establishments where production occurred—for example, whether a particular farm complies with land-use, environmental, or labor laws applicable to that site.
Companies must therefore be able to link products to those production sites and demonstrate—on the basis of adequately conclusive and verifiable information—that production at those locations complied with the applicable legal framework.19See EUDR (2025 consolidated version), Article 9(1).
In Brazil’s cattle sector, this requirement would extend across a broad body of law governing the legal use of land and the conditions of production, including constitutional protections for the environment and Indigenous peoples, the Forest Code and related environmental legislation, land tenure and regularization rules, environmental licensing requirements, embargo regimes, and labor laws, including prohibitions on forced labor. In supply chains where cattle pass through multiple establishments, this would require assessing legality across multiple upstream locations.20See, e.g., ClientEarth, Michael Rice and Raphaëlle Godts, Was it produced legally? Applying the legality requirement in the EU Deforestation Regulation to soy and cattle from Brazil, April 2025, pp. 3–5, 8–13, https://www.clientearth.org/media/iy0nfrg0/was-it-produced-legally_brazil_clientearth_april-2025.pdf, which highlights, among others: the 1988 Federal Constitution (including Articles 225 and 231); the Forest Code (Law No. 12,651/2012); the National Environmental Policy (Law No. 6,938/1981); the Environmental Crimes Law (Law No. 9,605/1998); land tenure and regularization laws; conservation unit legislation (Law No. 9,985/2000 and Decree No. 4,340/2002); Indigenous rights legislation and ILO Convention No. 169 implementation decrees; environmental embargo rules (Decree No. 6,514/2008); environmental licensing rules (CONAMA Resolution No. 237/1997); labor legislation, including forced labor prohibitions; the “dirty list” registry of slave labor; and pesticide and biosafety laws.
(3) That All Relevant Production Sites Have Been Identified and Geolocated
The Regulation requires operators to collect, in the case of cattle, the geolocation of all establishments where the animals were kept.21See EUDR (2025 consolidated version), Article 9(1)(d).
This requires identifying and geolocating all production sites relevant to compliance, including upstream establishments through which cattle passed before slaughter. In supply chains where cattle pass through multiple establishments, this requirement extends to indirect suppliers, whose identification and geolocation are necessary to demonstrate compliance.
(4) That the Information Supporting Compliance is Adequately Conclusive and Verifiable
Operators must collect “adequately conclusive and verifiable information” demonstrating compliance with the Regulation.22See EUDR (2025 consolidated version), Article 9(1)(h).
This establishes a high evidentiary threshold requiring corroborated, multi-source information capable of substantiating conclusions about deforestation status and legality across all relevant production sites. Supplier declarations may contribute to the evidentiary record, but cannot, on their own, substantiate compliance where independent verification is required.
(5) That a Risk Assessment Supports a Conclusion of No or Only Negligible Risk
Products may be placed on the EU market only where operators conclude, on the basis of the information collected, that there is no risk or only a negligible risk of non-compliance.23See EUDR (2025 consolidated version), Article 10.
This assessment is the central decision point in the due diligence system. It must take into account factors such as country risk classification, forest presence, governance conditions, the presence of Indigenous peoples, and supply-chain complexity, and must be grounded in a reasoned and documented evaluation of the information available. In practice, this assessment plays a central role in determining whether products can be placed on the market, making the completeness and reliability of the underlying information critically important.
(6) That Risk Mitigation Measures Have Been Adopted Where Risk is More Than Negligible
Where the risk assessment does not support a negligible-risk conclusion, operators must adopt effective risk mitigation measures before placing products on the market.24See EUDR (2025 consolidated version), Article 11.
These measures may include obtaining additional information, conducting independent surveys or audits, or taking other steps sufficient to reduce the risk. For operators that are not small or micro enterprises, this also includes maintaining formal due diligence systems, including internal procedures, management responsibility, and independent auditing.
(7) That a Due Diligence Statement Has Been Submitted and Documentation Retained
Products must be covered by a due diligence statement submitted through the EU information system.25See EUDR (2025 consolidated version), Articles 3(c), 4, 9–12, and 33. Operators (with the exception of micro and small enterprises) must also maintain a documented due diligence system, review their risk assessment at least annually,26See EUDR (2025 consolidated version), Article 10(4). and retain relevant information for at least five years.27See EUDR (2025 consolidated version), Article 12.
This requirement formalizes compliance as a legal declaration backed by supporting documentation and subject to review by competent authorities.
The EUDR establishes a public enforcement framework based on:
Administrative Supervision and Compliance Checks
Under this framework, enforcement is carried out primarily through administrative supervision by national competent authorities, operating on a risk-based basis. Authorities determine whether products placed on or exported from the EU market comply with the Regulation’s requirements, including that they are deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement.30See EUDR (2025 consolidated version), Articles 16 and 18 (requiring Member States to designate competent authorities and to carry out checks to ensure compliance with Article 3 requirements).
In practice, supervision involves both desk-based and on-the-ground checks. Authorities may review due diligence statements, the operator’s risk assessment and mitigation measures, assess operators’ due diligence systems, and examine the underlying evidence supporting compliance, including geolocation data, satellite monitoring, and other documentation. They may request additional information and carry out inspections where warranted.31See EUDR (2025 consolidated version), Articles 18 and 19 (empowering competent authorities to conduct checks, examine due diligence systems, verify information, and require operators to provide all necessary information and documentation); see also Articles 9–11 (establishing due diligence obligations, including information collection, risk assessment, and mitigation measures).
Compliance is tested through the ability to produce credible, product-specific evidence when requested.32See EUDR (2025 consolidated version), Article 9(1)(h), requiring operators to collect “adequately conclusive and verifiable information”; Mayer Brown, EU Regulation on Deforestation-free products (EUDR): What Lies Ahead in 2026?, 18 February 2026, https://www.mayerbrown.com/en/insights/publications/2026/02/eu-regulation-on-deforestation-free-products-eudr-what-lies-ahead-in-2026; CMS, EUDR Compliance Services, https://cms.law/en/deu/global-reach/europe/germany/expertise/compliance/esg-compliance/eudr-compliance. The absence of such evidence may itself trigger further scrutiny or preventive action.33See EUDR (2025 consolidated version), Article 17, on immediate interim measures. In practice, authorities assess whether the information provided is sufficient to support a conclusion of compliance on the basis of the available evidence, taking into account the nature of the supply chain and the risks identified.
Risk-Based Prioritization
This system is risk-based. Authorities prioritize checks based on factors such as the country of production, the commodity, and the operator’s risk profile.34See EUDR (2025 consolidated version), Articles 16–18, requiring competent authorities to carry out checks on a risk-based approach, taking into account country risk classification, commodity risk, and operator profiles.
Brazil is currently classified as a standard-risk country under the EUDR’s benchmarking system.35European Commission, Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 laying down rules for the application of Regulation (EU) 2023/1115 as regards the benchmarking system, Official Journal of the European Union, 22 May 2025, https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj. That classification does not reduce the obligation to assess risk at the level of specific commodities and supply chains. In the cattle sector, well-documented patterns of deforestation, weak traceability—particularly with respect to indirect suppliers—and documented human rights concerns mean that risk remains elevated in practice.36See, for instance, Climate Rights International, Before It’s Too Late: Curbing Cattle-Driven Deforestation and Rights Abuses in Brazil, Climate Rights International, October 2025, pp. 10–12 (traceability finding), Appendix A (cases), https://cri.org/wp-content/uploads/2025/10/CRI-Brazil-Report_Final.pdf; Climate Rights International, Brazil: Cattle Ranching, Forced Labor Driving Deforestation Ahead of COP30, Press Release, October 2025, https://cri.org/brazil-cattle-ranching-forced-labor-driving-deforestation-ahead-cop30/; Repórter Brasil, Under the Radar: How Cattle Ranchers Caught Employing Slave Labor Are Part of the Supply Chains of Brazil’s Largest Meatpacking Companies, Repórter Brasil, October 2025, case studies section, https://reporterbrasil.org.br; Mighty Earth, Rapid Response Report 5: Monitoring Deforestation in Brazilian Supply Chains, Mighty Earth, October 2025, p. 6, https://mightyearth.org/wp-content/uploads/2025/10/RapidResponse5Eng_.pdf; B. Slob et al., JBS, Marfrig, and Minerva: Material Financial Risk from Deforestation in Beef Supply Chains, Aidenvironment / Chain Reaction Research, December 2020, p. 1, https://www.aidenvironment.org/wp-content/uploads/2021/07/JBS-Marfrig-and-Minerva-Material-financial-risk-from-deforestation-in-beef-supply-chains-4.pdf; Forest Trends, Illegal Deforestation for Forest Risk Commodities Dashboard: Brazil, Forest Trends, 2022, pp. 2, 5, https://www.forest-trends.org/wp-content/uploads/2022/01/FRC-Legality-Risk-Dashboard-Brazil.pdf; Global Canopy, Floresta 250 – Cattle Baseline 2024, Global Canopy, December 2024, p. 6, https://floresta250.forest500.org/wp-content/uploads/sites/2/2024/12/Floresta-250-Cattle-baseline-2024-The-key-players-influencing-deforestation-in-Brazilian-cattle-supply-chains.pdf; Fern, How to Achieve Zero Deforestation in the Cattle Sector, Fern, 2023, p. 3, https://www.fern.org/fileadmin/uploads/fern/Documents/2023/How_to_achieve_zero_deforestation_in_the_cattle_sector.pdf. As a result, products sourced from these supply chains are more likely to be subject to scrutiny, and companies will need to demonstrate compliance on the basis of robust, verifiable evidence.37See European Commission, EUDR country benchmarking system (classifying countries as low, standard, or high risk); see also ClientEarth, Michael Rice and Raphaëlle Godts, Was it produced legally? Applying the legality requirement in the EU Deforestation Regulation to soy and cattle from Brazil, April 2025, pp. 3–5, 8–13, https://www.clientearth.org/media/iy0nfrg0/was-it-produced-legally_brazil_clientearth_april-2025.pdf.
Third-Party Submissions and Early-Stage Scrutiny
In addition to authority-initiated checks, the EUDR allows third parties to submit information indicating potential non-compliance.38See EUDR (2025 consolidated version), Article 31, providing that any natural or legal person may submit substantiated concerns to competent authorities, which must assess them. Where submissions are considered sufficiently substantiated, competent authorities must assess them and may initiate further checks and investigations. Where non-compliance is identified, authorities may adopt interim measures or require operators not to place or make available the relevant products on the market.39See EUDR (2025 consolidated version), Articles 16, 17, and 31, requiring authorities to assess substantiated concerns and permitting the adoption of interim or preventive measures, including suspension of placing or export where potential non-compliance is detected. Enforcement can therefore be triggered before violations are definitively established.40See also EUDR (2025 consolidated version), Article 17, on immediate interim measures.
Civil and Criminal Liability Exposure Under National Law
While the Regulation does not create a standalone civil liability regime,41See EUDR (2025 consolidated version), Articles 16–25 (establishing administrative supervision, corrective measures, and penalties), which do not include provisions for a harmonized civil liability regime at EU level. its administrative checks and due diligence requirements can facilitate civil claims under national legal systems by generating evidence and helping define the standards against which corporate conduct is assessed.42See European Commission, Guidance Document for Regulation (EU) 2023/1115 on deforestation-free products, OJ C 2025/4524, 12 August 2025, pp. 13–16, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:C_202504524; ClientEarth, Was it produced legally? Understanding the legality requirement in the EU Deforestation Regulation and how to implement it, April 2025, pp. 5, 8–12, https://www.clientearth.org/media/f4lbqll1/was-it-produced-legally_part-1_clientearth_april-2025.pdf. In practice, failures to meet the Regulation’s requirements—particularly gaps in traceability, inadequate due diligence, or the inability to substantiate compliance—may give rise to exposure under domestic legal systems. Evidence (or, more precisely, a summary of illegal activities) generated through administrative supervision may be relied upon in judicial proceedings.43Article 25, EUDR establishes that the Commission must publish information on judgments on its website, including the name of the company, the date of the judgment, a summary of illegal activities, and the penalties imposed. See EUDR (2025 consolidated version), Article 25(3). As courts in several European jurisdictions increasingly examine conduct in global supply chains, deficiencies in oversight and risk management may form the basis of civil claims alongside regulatory action.
What is more, the same conduct covered by the EUDR may also be characterized as a crime in a number of European jurisdictions under the New Directive of Environmental Crimes44Directive 2024/1203, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024L1203.—including in relation to unlawful deforestation.
Taken together, administrative checks, third-party submissions, risk-based prioritization, as well as exposure to civil and criminal liability create continuous, multi-source scrutiny. Compliance may be examined from multiple directions and at different stages of the supply chain.
Triggering Regulatory Scrutiny
Under the EUDR framework, civil society actors can play a central role in triggering and shaping enforcement. A wide range of third parties—including NGOs, trade unions, affected communities, and other interested actors—may submit substantiated concerns to competent authorities.45See EUDR (2025 consolidated version), Article 31, providing for submission of substantiated concerns by any natural or legal person. These submissions do not need to establish a complete case. Where competent authorities obtain or are made aware of relevant information, including substantiated concerns indicating a potential case of non-compliance, they are required to assess that information and take appropriate action.46See EUDR (2025 consolidated version), Article 16.12.
This mechanism creates a structured pathway for external actors to direct regulatory attention to specific companies, supply chains, or regions.47See EUDR (2025 consolidated version), Articles 18 and 31, requiring competent authorities to assess substantiated concerns and initiate checks where appropriate. In practice, it allows information about potential non-compliance—such as links to deforestation or unlawful land use—to be assembled and submitted in a form that can prompt administrative checks, inspections, or preventive measures.
Generating Evidence and Public Pressure
Civil society actors also operate beyond formal submissions. Through investigations, public reporting, and advocacy, they generate evidence that feeds into regulatory processes and shapes enforcement priorities. These channels often operate in combination. Information developed through civil society investigations may be submitted to authorities to trigger checks, made public to generate commercial pressure, and relied upon in legal proceedings.48See Mayer Brown, EU Regulation on Deforestation-free products (EUDR): What Lies Ahead in 2026?, 18 February 2026; CMS, EUDR Compliance Services (noting evidentiary and compliance implications of EUDR due diligence systems for broader legal exposure).
Litigation and Escalation of Risk
In parallel, civil society actors may initiate or support litigation under domestic legal frameworks, drawing on the standards reflected in the EUDR and the evidentiary record developed through administrative supervision.49As mentioned above, Article 25, EUDR establishes that the Commission must publish information on judgments on its website, including the name of the company, the date of the judgment, a summary of illegal activities, and the penalties imposed. See EUDR (2025 consolidated version), Article 25(3). Over time, this creates a reinforcing dynamic: administrative processes generate evidence that may be used in litigation, while civil society investigations and complaints help direct regulatory attention.
The practical consequence is that scrutiny can arise early and from multiple directions. Companies may be required to respond to information requests and demonstrate compliance in formal checks initiated ex officio by authorities, that is, on the basis of their own risk assessments or other information, as well as in response to external reporting, complaints, and potential legal claims.
The EUDR will be enforced through administrative decisions determining whether products may enter, remain in, or be removed from the EU market. For operators, the central risk will be evidentiary: whether they can demonstrate, on the basis of sufficiently reliable and verifiable information, that their products meet the conditions set out in Article 3. Where they cannot do so, products may be excluded from the EU market.50See EUDR (2025 consolidated version), Article 3 (setting out the conditions for placing products on the EU market), together with Articles 8–11 (establishing due diligence obligations including information collection, risk assessment, and mitigation).
In beef and, possibly, in leather51On July 13, 2026, the European Commission adopted a Delegated Act proposing the removal of hides and skins from Annex I of the EUDR (European Commission, Commission Delegated Regulation (EU) …/… of 13 July 2026 amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products, C(2026) 4920 final). The Act remains under review by the EU Parliament and the EU Council. supply chains, this standard is likely to be particularly demanding. Compliance will often require linking products to multiple production sites, reconstructing animal movements, and substantiating legality across environmental, land, and labor dimensions. The decisive question will not simply be whether an operator has adopted a due diligence system, but whether competent authorities are satisfied, on the basis of the available evidence, that the products meet the Regulation’s requirements.
Decisions Based on Available Evidence
Decisions on compliance will be taken by Member State competent authorities following risk-based checks that may focus on operators, traders, or specific products.
Authorities will assess whether the available evidence is sufficient to support a finding of compliance. Where it is not, products may be restricted, removed from the market, or otherwise subject to corrective measures. Gaps in traceability, incomplete or inconsistent information, or unresolved legality issues may themselves be sufficient to prevent a finding of compliance.52See EUDR (2025 consolidated version), Article 9(1)(h) (requiring the collection of “adequately conclusive and verifiable information”); Mayer Brown, EU Regulation on Deforestation-free products (EUDR): What Lies Ahead in 2026?, 18 February 2026.
Therefore, inability to demonstrate compliance on the basis of adequate due diligence and supporting evidence may itself lead authorities to conclude that products cannot lawfully be placed on the market.53See EUDR (2025 consolidated version), Articles 3(c), 9-12 (requiring the production of information).
Early Intervention and Immediate Disruption
The decision-making process will unfold in stages. Where there is a potential risk of non-compliance, competent authorities may adopt immediate interim measures under Article 23, including the seizure of products or the suspension of their placing on, or export from, the EU market.54See EUDR (2025 consolidated version), Article 23 (providing for interim measures, including seizure of products and suspension of their placing on, or export from, the EU market).
These measures may be imposed, therefore, before non-compliance is definitively established.
Loss of Market Access and Financial Consequences
Where non-compliance is identified, competent authorities are required to adopt corrective measures without delay and to bring the non-compliance to an end, as expressly provided in the EUDR.
Corrective measures expressly stipulated in the EUDR may include:55See EUDR (2025 consolidated version), Article 24 (requiring competent authorities to order corrective measures, including withdrawal, recall, or disposal of non-compliant products).
The EUDR also requires Member States to provide for penalties that are effective, proportionate, and dissuasive. These may include:56See EUDR (2025 consolidated version), Article 25 (providing for effective, proportionate, and dissuasive penalties).
Corrective measures are aimed at specific non-compliant products: they remove identified goods from the market. Penalties can go further. Where non-compliance reflects broader failures in the operator’s traceability or due diligence system, they may restrict the operator’s ability to place other products on the market until it can demonstrate compliance. (For example, if an importer cannot reliably trace the origin of one container of beef because its cattle-tracking system is deficient, the problem may not be limited to that container; the company may also be prevented from placing additional beef products on the EU market until it can show that its system can reliably identify compliant sourcing.)57See EUDR (2025 consolidated version), Article 9 (requiring operators to produce certain information along the due diligence process).
In practice, this means that products may be removed from the market and additional products blocked from sale until compliance can be demonstrated.
Civil and Criminal Liability Under Domestic Laws
As mentioned above, operators may also face civil liability exposure under domestic legal systems arising from the same factual circumstances that give rise to non-compliance under the EUDR. While the EUDR does not establish a harmonized civil liability regime at EU level, its investigations, and due diligence requirements may facilitate such claims by generating evidence. They may also help define the standards against which corporate conduct is assessed,58See EUDR (2025 consolidated version), Articles 16–25 (establishing an administrative enforcement framework without a harmonized EU-level civil liability regime); Mayer Brown, EU Regulation on Deforestation-free products (EUDR): What Lies Ahead in 2026?, 18 February 2026; CMS, EUDR Compliance Services (noting potential exposure to civil claims under domestic legal systems in connection with due diligence failures and misleading claims). provoking again a possible increase in civil claims. Such claims may arise from environmental harm, unlawful land use, labor abuses, or misleading commercial practices, particularly where companies represent products as “deforestation-free,” “legal,” or “EUDR-compliant” without being able to substantiate those claims.
In addition to administrative penalties and potential civil liability, some conduct underlying EUDR violations may also give rise to criminal exposure under national laws implementing the EU Environmental Crime Directive. The Directive strengthens criminal enforcement against serious environmental offences and provides enhanced penalties for particularly severe cases involving widespread, substantial, irreversible, or long-lasting damage to ecosystems. While non-compliance with the EUDR does not automatically constitute an environmental crime, evidence of unlawful deforestation or other serious environmental harm identified through EUDR enforcement may become relevant in criminal investigations and proceedings under national law.59Directive 2024/1203, Articles 3(1), 3(3), 7, 8, 10 and 11, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024L1203.
Implications for Beef (and Possibly Leather) Supply Chains
These risks are likely to be amplified in beef (and possibly leather) supply chains due to the structure of production. Cattle frequently pass through multiple establishments, and compliance will often depend on verifying deforestation status and legality across each of those locations.
Failures involving indirect suppliers, missing geolocation data, incomplete movement records, or unresolved legality issues are likely to undermine the ability to demonstrate compliance. Where such gaps exist, authorities may be unable to conclude that there is no or only negligible risk of non-compliance, and products may be excluded from the EU market.60See European Commission, Guidance Document for Regulation (EU) 2023/1115, 2025 (confirming that compliance must be supported by “adequately conclusive and verifiable information”).
In practice, the inability to demonstrate compliance—particularly in complex, multi-tier supply chains—may lead to exclusion from the market, even where companies have taken steps to address risks, if those steps do not provide a sufficient basis to demonstrate compliance.
Compliance with the EUDR is ultimately an evidentiary test: operators must be able to demonstrate, on the basis of adequately conclusive and verifiable information, that the products they place on the EU market meet the Regulation’s requirements and that there is no or only negligible risk of non-compliance. In complex supply chains such as beef in Brazil, this requires more than supplier assurances or partial traceability. It requires the ability to identify all relevant production locations, verify deforestation status and legality across those locations, and substantiate those conclusions with reliable, location-specific data. Where that cannot be done, products may be excluded from the EU market.
The EU Forced Labour Regulation (FLR) establishes an EU-wide prohibition on importing, placing, making available on, or exporting from the EU market any product made with forced labor.61European Parliament and Council, Regulation (EU) 2024/3015, Article 3. The prohibition applies equally to imported products, products manufactured within the EU, and products exported from the EU.
The prohibition is product-based: if forced labor contributed to a product at any stage of its production, that product may not be imported or placed on or exported from the EU market. This applies irrespective of where the forced labor occurred and regardless of whether it took place at the level of direct or indirect suppliers.62European Parliament and Council, Regulation (EU) 2024/3015, Article 3, and Recitals 17-18.
The Regulation adopts the definition of forced labor set out in Article 2 of the International Labour Organization (ILO) Convention No. 2963European Parliament and Council, Regulation (EU) 2024/3015, Article 2, and Recital 1.
all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.
This definition has three core elements, which apply regardless of the worker’s status or circumstances: (i) work or service; (ii) the presence of a “menace of penalty”; (iii) the absence of voluntary and informed consent.64The Regulation establishes that “forced labour” means forced or compulsory labour as defined in Article 2 of ILO Convention No 29, including forced child labour. European Parliament and Council, Regulation (EU) 2024/3015, Article 2(1). ILO Convention n. 29, Article 2(1) says: “For the purposes of this Convention the term forced or compulsory labour shall mean all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.” In practice, coercion may take many forms, including debt bondage, threats, withholding of wages, or abuse of vulnerability.65European Parliament and Council, Regulation (EU) 2024/3015, Recital 1.
Adopted in 2024, the Regulation will become fully applicable in December 2027. The European Commission is expected to issue a database and a guidance, including on due diligence, in July 2026. This will provide further detail on how authorities and companies are expected to assess and address risks of forced labor in practice.
Covered Products and Stages of Production
The Regulation applies broadly across products, supply chains, and geographies:
Because the prohibition attaches to the product itself, forced labor at any point in the production chain—including at upstream or indirect suppliers—may render the final product prohibited.69European Parliament and Council, Regulation (EU) 2024/3015, Article 3, Recitals 17-18.
Forced Labor in Brazil’s Cattle Sector
Forced labor and other severe forms of labor exploitation have been chronic and widespread in Brazil’s cattle sector. Since 1995, Brazilian federal authorities have rescued more than 17,000 workers from cattle ranches in conditions classified as “trabalho análogo à escravidão” (conditions analogous to slavery), representing roughly one-third of all such rescues in the country over that period. While this legal category is broader than the definition of forced labor under international law, it frequently involves coercive practices—such as debt bondage, threats, and severe restrictions on freedom—that fall within the definition used by the ILO. Federal officials and rights advocates emphasize that these cases likely represent only the “tip of the iceberg,” as most abuses occur in remote areas and go undetected.70Climate Rights International, Chapter II: Forced Labor and Labor Exploitation, Before It’s Too Late: Curbing Cattle-Driven Deforestation and Rights Abuses in Brazil, October 2025, p. 27.
There is a well-documented correlation between forced labor and cattle-driven deforestation in the Amazon. Reported cases are concentrated in the “arc of deforestation,” where forest clearing is most intense. A review of nearly 1,000 cases of labor abuses in the cattle sector found that properties using forced labor or analogous practices were more likely to be located in remote, forested areas and to exhibit significantly higher rates of deforestation.71Climate Rights International, Before It’s Too Late: Curbing Cattle-Driven Deforestation and Rights Abuses in Brazil, October 2025, p. 31.
This pattern reflects the economic structure of frontier expansion. Clearing forest requires both capital-intensive machinery and labor-intensive manual work. To reduce costs, operators engaged in illegal deforestation often rely on cheap, informal, and highly exploitable labor, typically recruited through intermediaries and employed without contracts.
Workers are commonly brought to remote ranches through misleading recruitment practices, including false promises of wages and formal employment. Upon arrival, they may face degrading conditions, including unpaid or underpaid labor, unsafe work, inadequate shelter, and lack of basic services. Employers then rely on debt bondage, geographic isolation, and/or threats or violence to prevent workers from leaving. These mechanisms correspond to indicators—or warning signs—of possible forced labor identified by the ILO, including restriction of movement, abuse of vulnerability, and intimidation.72ILO, Indicators of Forced Labour, Geneva: International Labour Organization, 2025.
Animals frequently pass through multiple properties before slaughter, including remote upstream ranches where monitoring is weakest. These structural conditions make forced labor difficult to detect in cattle supply chains. As a result, even where direct suppliers are subject to screening, risks of forced labor may remain embedded in upstream segments of the supply chain—particularly in regions associated with deforestation and frontier expansion.
The FLR establishes a risk-based investigation framework under which competent authorities identify, prioritize, and investigate products that may have been made with forced labor.
Preliminary Assessment and Prioritization
Authorities conduct a preliminary assessment to determine whether to proceed towards a formal investigation,73European Parliament and Council, Regulation (EU) 2024/3015, Article 14(1). where they will consider:
These are, therefore, factors to be taken into account in prioritizing cases for a formal investigation.
Formal Investigation
Authorities may open a formal investigation and request “any information that is relevant and necessary for the investigation, including information identifying the products under investigation and, where appropriate, identifying the part of the product to which the investigation should be limited, as well as the manufacturer, producer, product supplier, the importer or the exporter of those products or parts thereof.”78European Parliament and Council, Regulation (EU) 2024/3015, Article 18(3). Because the prohibition applies at any stage of production, such investigations extend to upstream and indirect suppliers.79European Parliament and Council, Regulation (EU) 2024/3015, Article 3, and Recitals 17-18.
In supply chains such as those in Brazil’s cattle sector, this is especially significant, as mentioned in the previous section.
These investigatory powers have direct implications for companies placing products on the EU market. The European Commission is expected to issue guidance on due diligence under the FLR, but companies do not need to wait for that guidance to understand what will be required in practice. Although the Regulation does not formally impose additional due diligence obligations, its product-based prohibition has clear practical implications. In practice, companies’ ability to identify and exclude links to forced labor in their supply chains—and to demonstrate this if investigated—is likely to be critical in limiting exposure to adverse decisions and regulatory consequences.
From December 14, 2027, investigations may be started. Companies therefore have a limited window to ensure that their supply chains are capable of generating the information needed to respond to investigations—and should begin building that capacity now.
In practice, companies sourcing from high-risk sectors such as Brazil’s cattle industry face two central challenges:
(1) Tracing Products Through Indirect Suppliers
If investigated, a company will be required to provide information tracing the products under investigation through upstream and indirect suppliers in order to demonstrate compliance with the FLR.80European Parliament and Council, Regulation (EU) 2024/3015, Articles 17(1) and 20(2).
Because cattle in Brazil frequently pass through multiple ranches before slaughter, responding effectively to such requests will in practice require companies to identify the chain of farms—including indirect suppliers—connected to the products under investigation.
Although the FLR does not explicitly require geolocation data, companies that cannot link upstream suppliers to specific locations may fail to detect and avoid links to forced labor.
(2) Showing Products are not Linked to Forced Labor
In an investigation, competent authorities may require economic operators to provide “any information that is necessary to determine whether products were made with forced labour.”81European Parliament and Council, Regulation (EU) 2024/3015, Article 18(3). Even before formal investigations are started, authorities may request “any information that is necessary to determine whether the products were made with forced labour.” European Parliament and Council, Regulation (EU) 2024/3015, Article 17(1). Where sufficient information cannot be obtained from the operator, authorities may determine whether Article 3 has been violated “on the basis of any other facts available.”82European Parliament and Council, Regulation (EU) 2024/3015, Article 20(2). The Regulation provides that this may arise, in particular, where an operator refuses to provide requested information without justification, fails to do so within prescribed time limits, provides incomplete or incorrect information with the objective of blocking the investigation, provides misleading information, or otherwise impedes the investigation.83European Parliament and Council, Regulation (EU) 2024/3015, Article 20(2).
In practice, companies, if investigated, must be able to provide information about their supply chains. Where they cannot—because they lack visibility into upstream segments or cannot produce relevant documentation—they may be unable to address concerns that their products are linked to forced labor. In sectors such as Brazil’s cattle industry—where supply chains are complex and opaque—this creates a significant likelihood that companies will be unable to demonstrate that their products are not linked to forced labor.
Civil society actors are likely to play an active role in testing whether companies can meet the requirements of the Regulation.
(1) Triggering and Informing Regulatory Investigations
Under the FLR, any natural or legal person may submit information through the Commission’s single submission point,84European Parliament and Council, Regulation (EU) 2024/3015, Article 9(2). as long as the information is not “incomplete, unfounded, or made in bad faith.”85European Parliament and Council, Regulation (EU) 2024/3015, Article 9(3).
This low threshold means that enforcement may be initiated on the basis of credible indications of risk, rather than conclusive proof of a violation.
As a result, civil society actors can act as initiators of enforcement,86European Parliament and Council, Regulation (EU) 2024/3015, Article 14(3)(d) and (f). particularly in sectors where risks are concentrated in upstream segments of complex and opaque supply chains. In the case of Brazil’s cattle industry, where forced labor is often linked to remote ranches and indirect suppliers, civil society actors may be especially well placed to assemble and present relevant information.
Once an investigation is underway, civil society actors may continue to contribute to the evidentiary record87European Parliament and Council, Regulation (EU) 2024/3015, Article 18(5).—for example, by documenting conditions in upstream supply chains, identifying links between operators and high-risk regions or practices, and providing field-based evidence and analysis.
(2) Amplifying Scrutiny and Commercial Pressure
Beyond their role in formal procedures, civil society actors may also contribute to enforcement by amplifying scrutiny and increasing pressure on companies.
Public reporting, advocacy campaigns, and engagement with investors, business partners, and regulators can increase the visibility of risks associated with particular supply chains. In cases where companies are unable to provide clear and credible information about their sourcing, such scrutiny may have commercial consequences, including reputational harm, changes in buyer behavior, or investor engagement.
In this way, civil society action can operate in parallel with formal enforcement processes, reinforcing the incentives created by the Regulation and accelerating responses by market actors.
(3) Litigation and Cumulative Legal Risk
Civil society actors may also act as litigants or facilitators of litigation before domestic courts. While the FLR itself establishes only an administrative enforcement regime, information produced under the FLR framework may be useful in civil proceedings. For instance, interpretations of what could constitute existing due diligence obligations88While the FLR does not create new due diligence obligations, the Commission’s Guidance on Due Diligence may be useful to assess existing due diligence obligations regarding forced labor in civil proceedings. European Parliament and Council, Regulation (EU) 2024/3015, Articles 1(3) and 11(a,f). will be publicly available through the Commission’s Guideline on Due Diligence. Likewise, final decisions banning products89Publicly available information will encompass final decisions on banning products (Articles 12(f) and 20). European Parliament and Council, Regulation (EU) 2024/3015, Articles 12(f) and 20. will also be made public and may serve as relevant evidence in civil litigation.
Courts in several European jurisdictions have shown an increasing willingness to examine corporate conduct occurring abroad under domestic legal frameworks, including statutory regimes (such as the French Duty of Vigilance law and the German Due Diligence Act) and general principles of tort or negligence (e.g., in the UK, the Netherlands, and Italy). In that context, documentation generated through FLR enforcement may contribute to broader judicial scrutiny of companies sourcing from high-risk sectors or regions.
Implications
Enforcement under the FLR is therefore not limited to public authorities. In practice, civil society actors can act as catalysts for scrutiny, increasing the likelihood that risks are identified and brought to the attention of regulators and market actors.
In supply chains characterized by limited traceability—such as those in Brazil’s cattle sector—this increases the likelihood that gaps in oversight or documentation will be exposed and subjected to regulatory, commercial, and legal pressure.
Where authorities determine, based on factual, objective, and verifiable information90European Parliament and Council, Regulation (EU) 2024/3015, Articles 2(16) and 30. that forced labor contributed to a product at any stage of production, they must prohibit its import and placement on the EU market or its export from that market.91European Parliament and Council, Regulation (EU) 2024/3015, Article 20(4). They may also require that products already placed or made available on the market be withdrawn and that affected goods be disposed of.92European Parliament and Council, Regulation (EU) 2024/3015, Article 20(4).
Customs authorities must enforce these decisions by suspending release for free circulation or export where appropriate, and, after a final decision, seizing the product.93European Parliament and Council, Regulation (EU) 2024/3015, Article 28-30.
In addition to these administrative consequences, companies may also face significant commercial and legal risks, concerning supply-chain disruption, reputational harm,94Decisions will name economic operators. European Parliament and Council, Regulation (EU) 2024/3015, Articles 20-22. loss of market access, and civil proceedings drawing on the standards of conduct through FLR enforcement.
For companies placing products on the EU market, compliance with the FLR ultimately depends not on the existence of corporate policies or voluntary commitments, but on whether they can provide the information necessary to demonstrate, if investigated, that the products they place on the market are not linked to forced labor at any stage of their production chain. Because the prohibition is product-based and extends throughout the entire chain of production, this will often require companies to identify upstream and indirect suppliers, obtain sufficient visibility into high-risk segments of their supply chains, and provide the relevant and necessary information requested by competent authorities during an investigation.
Where it is not possible to gather the relevant information and evidence, including because an economic operator or public authority refuses or fails to provide requested information without valid justification, provides misleading information, or otherwise impedes the investigation, competent authorities may establish that Article 3 has been violated on the basis of any other facts available.
Objectives
The Corporate Sustainability Due Diligence Directive (CSDDD), as amended in 202695European Parliament and Council, Directive (EU) 2026/470 of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirements (Omnibus I Directive), Official Journal of the European Union, 26 February 2026, https://eur-lex.europa.eu/eli/dir/2026/470/oj. establishes that EU Member States should regulate large companies96A few of the companies within the scope of the Directive can be found here: Centre for Research on Multinational Corporations (SOMO), CSDDD Datahub: Search for a Company, https://www.somo.nl/csddd-datahub/. by imposing the obligation to identify, prevent, mitigate, bring to an end, and remediate adverse human rights and environmental impacts arising from their own operations, those of their subsidiaries, and, where related to their chains of activities, those of their business partners.
Unlike product-based prohibitions, the Directive operates through a conduct-based regime: the legal violation is not the existence of a harm, but the failure of companies to take appropriate measures to identify and address adverse impacts in accordance with the Directive’s due diligence obligations.
The Directive therefore creates a continuous obligation of risk management, rather than a one-time compliance requirement. Companies must integrate due diligence into policies, identify risks, take preventive and corrective measures, monitor effectiveness, communicate publicly, and remediate adverse impacts.97Directive (EU) 2024/1760, Articles 5-11, 13, Official Journal of the European Union, 5 July 2024.
Timeline
The Directive entered into force following its publication in the Official Journal of the European Union on July 5, 2024. Member States are required to transpose the Directive into national law by July 26, 2028. The substantive due diligence obligations are expected to apply from 2029.98European Parliament and Council, Directive (EU) 2026/470 of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirements (Omnibus I Directive), Official Journal of the European Union, 26 February 2026, Recital 46. See also, Directive (EU) 2024/1760, as amended (consolidated version), Article 37, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02024L1760- 20260318&qid=1777304496250.
This is what large companies based in the EU or abroad (e.g., EU companies with more than 5,000 employees and an annual net worldwide turnover of over 1.5 billion euros, or non-EU companies with an annual net EU turnover of over 0.5 billion euros) will or could be required to demonstrate:
(1) Tracing Supply Chains to Upstream and Indirect Suppliers
Companies must be able to identify where in their chain of activities the adverse impacts covered by the Directive are most likely to occur and to be most severe, using reasonably available information and taking into account sectoral and geographic risk factors.99Directive (EU) 2024/1760 (2026 consolidated version), Articles 5-9.
Companies must begin with a scoping exercise, based on reasonably available information, to identify high-risk areas of the supply chain, and carry out an in-depth assessment in those areas.100Directive (EU) 2024/1760 (2026 consolidated version), Articles 5-9.
Where severe adverse impacts are linked to specific upstream suppliers, companies will be required to identify those suppliers to the extent necessary to assess those impacts.
Where companies are unable to trace their supply chains to indirect suppliers, particularly in higher-risk areas, this will significantly limit their ability to identify relevant adverse impacts—and, consequently, to demonstrate compliance with the Directive’s due diligence requirements.101Directive (EU) 2024/1760 (2026 consolidated version), Articles 5-12, 25.
(2) Environmental and Human Rights Impacts
The adverse impacts covered by the Directive include “specified” environmental impacts, and environmental degradation that harms human rights102Directive (EU) 2024/1760 (2026 consolidated version), Annex Part II., taking place across the chain of activities.
The adverse impacts also include human rights impacts103Directive (EU) 2024/1760 (2026 consolidated version), Annex Part I across the chain of activities, such as forced labor, land-related abuses, and impacts on communities.
In sectors such as Brazil’s cattle industry, environmental impacts, particularly deforestation, and human rights impacts, are tied to specific locations and production sites, including individual farms and ranches. Identifying, assessing, and addressing those impacts therefore depends on determining where production is taking place.
While the Directive does not impose a formal requirement to collect geolocation data, risks are geographically determined. Companies must be able, therefore, to link upstream suppliers to their locations. Without that information, they cannot meaningfully assess geographic risk or determine whether production is occurring in areas associated with heightened environmental concerns, such as deforestation, or link their supply chains to available data identifying such risks.104Directive (EU) 2024/1760 (2026 consolidated version), Articles 3(1)(c)(u) and 8(2).
(3) Monitoring, Documentation, and the Ability to Demonstrate Compliance
Companies must take appropriate measures aimed at preventing, mitigating, and/or bringing adverse impacts to an end.105Directive (EU) 2024/1760 (2026 consolidated version), Article 5.
They must also monitor the effectiveness of their due diligence measures and maintain credible documentation demonstrating compliance with their obligations.106Directive (EU) 2024/1760 (2026 consolidated version), Article 5(1)(g).
In practice, companies must be able to demonstrate how they have identified, assessed, prevented, and addressed adverse impacts across their chain of activities, including upstream and indirect suppliers. This includes showing:
The CSDDD establishes an enforcement framework centered on administrative supervision by national authorities, a company mechanism, and civil liability.
Administrative Supervision by National Authorities
The Directive requires Member States to designate one or more regulatory authorities with powers to monitor compliance, request information, carry out investigations, and impose sanctions.111Directive (EU) 2024/1760 (2026 consolidated version), Articles 24 and 25.
Under Article 25, these authorities have broad powers, including the ability to require companies to provide detailed information on their due diligence processes, from risk assessment to measures taken, in accordance with the obligations set out in Articles 7– 16 of the Directive.112Directive (EU) 2024/1760 (2026 consolidated version), Article 25. Authorities will assess whether companies have taken appropriate measures in light of the risks they face.113Directive (EU) 2024/1760 (2026 consolidated version), Articles 3(1)(c)(o), 5, 10, 12, and 15.
Authorities are expected to assess compliance through a risk-based lens, focusing on whether companies have identified and addressed areas where adverse impacts are most severe and most likely to occur. In such contexts, authorities will not simply verify whether a company has adopted general policies or procedures. They will assess whether the company’s due diligence process is effective for identifying and addressing the specific risks associated with its operations and supply chains.
A central feature of this framework is that compliance is assessed primarily in terms of conduct rather than outcome. The Directive does not impose strict liability for the occurrence of adverse impacts, but it does require companies to demonstrate that they have taken appropriate measures to identify and address such impacts.114Directive (EU) 2024/1760 (2026 consolidated version), Articles 5, 7-16.In this way, harm may serve as evidence of non-compliance.
A Company’s Complaint Mechanism
Companies must also maintain internal complaint mechanisms through which affected persons and their representatives, including trade unions and civil society organizations, may raise concerns directly with the company.115Directive (EU) 2024/1760 (2026 consolidated version), Article 14. These mechanisms must be accessible and publicly available.116Directive (EU) 2024/1760 (2026 consolidated version), Article 14(3). External submissions and internal complaint mechanisms thus create multiple pathways through which potential noncompliance may be identified and escalated.
Determination of Non-Compliance
Competent supervisory authorities are responsible for determining whether a company has failed to comply with its obligations under the Directive. This assessment is based on whether the company has taken appropriate measures considering the risks it faces, including whether it has:
The concept of “appropriate measures” is context-specific. Authorities will assess corporate conduct in light of the severity and likelihood of impacts, as well as the information that was reasonably available to the company at the time.118Directive (EU) 2024/1760 (2026 consolidated version), Article 3(1)(o).
As a result, a finding of non-compliance may arise not only where companies fail to act, but also where they:
The occurrence of unaddressed adverse impacts plays a significant evidentiary role in this assessment. Where harm is documented and linked to areas that should have been identified as high risk, and the company has not identified and addressed that harm, it may indicate that the company’s due diligence process was inadequate121Directive (EU) 2024/1760 (2026 consolidated version), Articles 8-12.
Triggering Regulatory Scrutiny
Scrutiny under the Directive may be triggered not only by supervisory authorities acting on their own initiative, but also by information submitted by external actors. Natural or legal persons may submit “substantiated concerns” to competent authorities regarding actual or potential adverse impacts or failures to comply with due diligence obligations, prompting examination by regulatory authorities of the companies or supply chains concerned.122Directive (EU) 2024/1760 (2026 consolidated version), Article 25-26.
Generating Evidence and Public Pressure
Civil society actors can play an active role in driving scrutiny by identifying and documenting adverse impacts and gaps in corporate due diligence. This may include evidence relating to the existence of adverse human rights or environmental impacts, failures in corporate due diligence processes, inconsistencies between corporate disclosures and available evidence, or the inadequacy of measures taken.
Such information can be used to support substantiated concerns submitted to regulatory authorities or to challenge companies’ own representations regarding their due diligence. It may also be used to support advocacy, public reporting, and engagement with investors, business partners, and regulators. In practice, this can amplify scrutiny and increase pressure on companies, particularly where they are unable to provide clear and credible information about their due diligence processes.
Importantly, complainants are not required to establish a violation at the outset. Submissions may be made where there are reasonable grounds to believe that adverse impacts may occur or that a company may be failing to comply.123Directive (EU) 2024/1760 (2026 consolidated version), Article 26(1). They can identify high-risk areas, bring evidence to the attention of authorities, and shape the scope and direction of regulatory scrutiny, thereby increasing the likelihood that regulatory authorities take action. Information generated through these processes may also be used in civil proceedings under domestic law.
In addition to regulatory scrutiny and potential administrative penalties, the Directive expressly provides for civil liability under domestic law where damage results from a company’s failure to comply with its due diligence obligations.124Directive (EU) 2024/1760 (2026 consolidated version), Article 29.
For companies, this creates additional exposure where they fail to take appropriate measures required under the Directive, particularly in contexts where adverse impacts are documented and linked to areas that should have been identified as high risk.
In such cases, the central question is whether the company can demonstrate, on the basis of reliable and documented evidence, that it took appropriate measures to identify and address the most likely and severe impacts. Where it cannot, and where damage results from that failure, this may give rise to civil claims.
In practice, this means that deficiencies in a company’s due diligence processes may not only trigger regulatory scrutiny but also expose the company to civil claims brought by affected individuals or communities.
Where companies are unable to demonstrate that they have taken appropriate measures in light of the risks they face, they may be subject to multiple and cumulative consequences. These include administrative enforcement measures, financial penalties, exposure to civil liability, including damages awarded in litigation, and significant reputational and commercial harm.
Corrective Measures
Where non-compliance is identified, competent authorities may require companies to take corrective measures aimed at bringing their conduct into conformity with the Directive.125Directive (EU) 2024/1760 (2026 consolidated version), Article 11(3)(b).
These measures may include revising due diligence policies and procedures, expanding the scope or depth of risk assessments, strengthening preventive or mitigation measures, and improving monitoring and documentation systems.
Corrective measures can be forward-looking. Their purpose is not only to address past deficiencies but to ensure that the company’s due diligence system becomes capable of identifying and addressing risks in accordance with the Directive.
Administrative Penalties
In addition to corrective measures, regulatory authorities may impose administrative penalties for non-compliance.126Directive (EU) 2024/1760 (2026 consolidated version), Article 27. These penalties must be effective, proportionate, and dissuasive, and may take into account factors such as:
Under the Directive, fines may reach as high as 3% of net global turnover.128Directive (EU) 2024/1760 (2026 consolidated version), Article 27(4). For example, in the case of the smallest companies covered by the Directive, those with a net worldwide turnover of 1.5 billion euros, the maximum fine would exceed 45 million euros.
Civil Damages
In addition to administrative penalties, companies may face civil claims under domestic law that, if successful, may result in damages awarded in litigation.129Directive (EU) 2024/1760 (2026 consolidated version), Article 29. Where adverse impacts are documented and linked to areas that should reasonably have been identified as high risk, such claims may be more likely and may result in significant financial liability.
Reputational and Commercial Risks
In addition to legal sanctions, non-compliance with the Directive carries significant reputational and commercial risks.
The Directive requires companies to publicly communicate on their due diligence processes, including the measures they have taken and their effectiveness.130Directive (EU) 2024/1760 (2026 consolidated version), Article 16. This transparency increases the visibility of both compliance efforts and failures.
Where deficiencies are exposed, consequences may include:
In sectors where adverse impacts are already subject to public attention, these consequences may be particularly significant.
For EU and non-EU in-scope companies, compliance with the Directive turns on whether companies can effectively identify and address risks where they are most likely and most severe. The central question is whether companies can demonstrate, on the basis of credible and documented evidence, that they have taken appropriate measures in light of the risks they face.
In high-risk sectors such as the cattle supply chain in Brazil, this requires more than general policies or partial visibility. It requires the ability to obtain sufficient insight into supply chains beyond direct suppliers, to assess environmental and human rights risks in their geographic and operational context, and to rely on systems capable of identifying and appropriately addressing sources of harm in practice. Where such visibility and control are lacking, companies are unlikely to be able to demonstrate that they have taken appropriate measures and are therefore unlikely to be able to demonstrate compliance with the Directive’s due diligence requirements. In those circumstances, they are exposed to multiple and cumulative consequences, including administrative corrective measures, administrative penalties, civil liability, and reputational and commercial harm.
This report was researched and written by Climate Rights International legal consultant Daniela Ikawa. Daniel Wilkinson, Senior Policy Advisor, edited the report and was a co-author. The report was reviewed and edited by Executive Director Brad Adams, Legal Director Linda Lakhdhir, and Advocacy Director Lotte Leicht. Sakeena Razick and Marcela Gómez managed the report’s production.
Climate Rights International is grateful to the large number of people in Brazil and elsewhere who provided support, advice, and feedback for the project, including Dr. Amintas Brandão, Dr. Juliana Brandão, André Campos, Marcel Gomes, Rick Jacobsen, Heron Martins, Ricardo Negrini, Dr. Raoni Rajão, and Ben Vanpeperstraete.
We are also grateful to the Freedom Fund for its generous support for this project. The views expressed in the report are those of the authors and do not necessarily reflect those of the Freedom Fund.
Cover photo: A worker closes a gate in a cattle ranch in in São Félix do Xingu, Pará. Credit: Fernando Martinho for Climate Rights International.
