‘Contested Unilateralism: Brazilian Perspectives on the European Union Deforestation Regulation’ - A review

Earlier this year we wrote a report on the soy trade between China and Brazil. While collecting data, we spoke with government officials, academics, and NGOs about the European Union Deforestation Regulation (EUDR) as an alternative to China’s “no conditionality” approach to commodity imports and its implications for Brazil. Given Brazil’s central role in debates on tropical deforestation, and the prominence of environmental advocates across government, business, and civil society, we were surprised to encounter overwhelmingly negative views of the EUDR. With very few exceptions, everyone we talked to, including environmental activists, was anti-EUDR. Why was opposition so widespread? Niels Søndergaard, Johanne Døhlie Saltnes, Camila Dias De Sá, and Ana Flávia Barros-Platiau provide the answer.

In Contested Unilateralism: Brazilian Perspectives on the European Union Deforestation Regulation, the authors explore how Brazilian stakeholders perceive the EUDR and what those perceptions reveal about broader debates on environmental governance, sovereignty, and international rulemaking. Their study provides important insights into both the implementation of the EUDR and the future of transboundary environmental governance more generally.

The EUDR is one of the most ambitious attempts by a major consumer market to address tropical deforestation through trade policy. It requires companies placing commodities such as soy, cattle, coffee, cocoa, palm oil, rubber, and timber on the European Union (EU) market to demonstrate that these products are not linked to deforestation after 2020. While European policymakers present the regulation as a response to climate change and biodiversity loss, reactions among producer countries have been far less positive.

The authors argue that opposition in Brazil is often misunderstood. Most Brazilian actors do not reject the goal of reducing deforestation. Rather, they question how the regulation was designed, whose standards it reflects, and whether the EU is justified in setting rules with global effects through unilateral action. The debate therefore concerns not only environmental protection but also questions of legitimacy and participation in international governance.

The article situates the EUDR within wider debates about decolonization and the growing criticism of rules originating in the Global North. Although the EU traditionally portrays itself as a champion of multilateralism, the EUDR extends European regulatory influence through conditions placed on market access. From the EU perspective, this reflects responsibility for the environmental impacts of European consumption. For many producer countries, however, it appears as an expansion of European authority into matters affecting non-European economies and societies. The result is a difficult question: does the EUDR represent necessary climate action, or an updated form of external control?

Brazil provides an especially relevant case through which to examine these tensions. As a leading agricultural exporter and home to large portions of the Amazon and Cerrado biomes, Brazil occupies a central position in global deforestation debates. At the same time, Brazilian foreign policy has historically emphasized sovereignty and autonomy in international rulemaking. The country also contains a diverse range of stakeholders, including government agencies, diplomats, agribusiness representatives, environmental NGOs, consultants, and producer organizations.

Drawing on interviews conducted between 2023 and 2025, as well as official documents and public statements, the authors identify three forms of contestation: efficiency-based, validity-based, and procedural. Although all three are present, procedural concerns emerge as the greatest source of resistance.

Efficiency-based contestation focuses on whether the EUDR can actually reduce deforestation. Many stakeholders question whether a regulation imposed by a single consumer market can achieve meaningful results. If exporters simply redirect commodities to other destinations with less stringent requirements, trade flows may change without reducing forest loss. Critics also point to potentially high compliance costs and argue that stronger domestic enforcement may be more effective than additional trade restrictions. Environmental organizations share some of these concerns, noting that traceability requirements do not necessarily address deeper drivers of deforestation such as land tenure disputes, governance challenges, and inequality. At the same time, they warn that smaller producers may struggle to comply with the regulation.

Validity-based contestation concerns the norms embedded in the EUDR. Importantly, the authors find relatively little opposition to the principle of reducing deforestation itself. The Lula government has renewed commitments to environmental protection, NGOs support conservation efforts, and many agribusiness actors increasingly recognize sustainability as a commercial necessity. The main disagreement instead concerns the relationship between the EUDR and Brazil’s own legal framework. Brazil’s Forest Code permits some forms of land conversion under certain conditions, whereas the EUDR adopts a stricter standard and does not distinguish between legal and illegal deforestation after its cut-off date. Many Brazilian stakeholders therefore object not to environmental goals but to standards that effectively override nationally established legislation.

The article’s most significant contribution lies in its discussion of procedural contestation. Across government, civil society, and business, respondents expressed dissatisfaction with how the EUDR was developed. Many argued that producer countries had limited opportunities to influence the regulation despite being directly affected by it. Concerns about fairness, representation, and legitimacy therefore became central to the debate. From this perspective, the EU established rules with global implications through an internal legislative process that largely excluded non-European actors.

Brazilian officials articulated these concerns particularly strongly, portraying the EUDR as a form of unilateral rulemaking that insufficiently considered producer-country perspectives. Civil society organizations raised similar criticisms but focused more on the need for cooperation and local ownership. They argued that effective environmental governance requires collaboration among producers, consumers, governments, and communities, and warned that externally imposed rules may encounter resistance and weaken implementation. Some also viewed the EUDR as reflecting enduring Eurocentric dynamics, where standards are designed in the Global North while adjustment costs fall disproportionately on actors in the Global South. Agribusiness representatives echoed these concerns, arguing that the regulation gives insufficient recognition to Brazilian legal frameworks and existing conservation efforts.

At the same time, our own research revealed that stakeholders across all sectors view the Chinese approach of engaging producer countries and the co-designing technical solutions for deforestation-free commodities favourably. As observers of the global trade space will know, this represents (yet another) victory for Chinese soft power in the Global South – not a negligible point to score, in our contested geopolitical times.

Søndergaard, N., Saltnes, J. D., De Sá, C. D., & Barros-Platiau, A. F. (2026). Contested unilateralism: Brazilian perspectives on the European Union Deforestation Regulation. Globalizations. Advance online publication. https://doi.org/10.1080/14747731.2026.2725322