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In general, CSOs and members of VNGO-EVFTA and VNGO-FLEGT support the policy of implementing the Regulation on deforestration- free Products, but they have some recommendation as follow:

-    It is necessary to select the products that can cause a significant impact on deforestation and forest degradation. Avoid the products with little or no influence on the forest, like NTFP products which is also affected by this regulation, causing difficulties for people in the import and export process.

-      There should be an appropriate, simple yet effective implementation and monitoring mechanism.

-      Clarifying the advisory and supervisory role of CSOs in regulation implementation.

-      There should be a mechanism to support small and medium-scale enterprises and households

-      EU should support the enhancement of the national legal documents, using the international standards as the foundation for adjustment (restrict the act of deletion and renewal due to its challenging and time-wasting procedure.)

-    CSOs believe that the EU should define the criteria to prioritize countries that successfully ensure forest governance: preventing deforestation, forest degradation, and contributing to the NDC, NAP, etc.

-      CSOs support the continuation of forest law enforcement, forest governance, and trade in forest products (FLEGT) implementation.

-      CSOs found that the new regulations are stronger but more challenging to enforce in countries with underdeveloped technology platforms, where the majority of items were produced by small households (provides geographical location, production batches, etc..). It also results in a situation which benefits the intermediate traders.

-      The removal of green lanes will also create an obstacle for businesses, even the ones with successful trading history (adding unnecessary procedures for them)

-      The EU should state deforestation and forest degradation criteria for each type of forest to facilitate the CSOs' management.

-   Clarify the application of the regulations for each country. For instance, in Vietnam, exploitation of natural forests is banned; along with that, the management of afforested areas have a limited situation of deforestation and degradation.  The causes of forest loss in each country are also different. For example, Vietnam lost forests due to the shift to agriculture, infrastructure construction, hydropower, while Ghana lost forests due to gold mining. Or rubber trees in some countries...

-      Clarifying the methods for determining indicators of forest degradation, deforestation, and reduction of reservation areas.


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