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(English) ABIOVE´s comments on the document “Soy and environmental compliance in Brazil: an undervalued risk for global markets”

São Paulo, 31 de outubro de 2019


  1. The claim that soy is a driver of deforestation in Brazil is wrong.
    1. In the Amazon biome, thanks to initiatives such as the Soy Moratorium pact, to which the entity and its members are signatories, soy was responsible for only 1.4% of the Biome’s deforested area after 2008, the date of the Brazilian Forest Code. Soy Moratorium signatories do not source soybeans from these areas. This is an internationally recognized initiative that uses data from the National Institute for Space Research – INPE (PRODES Amazônia) to monitor soybean planting in deforested areas and with this information in hand, ABIOVE member companies have been guaranteeing a zero deforestation policy for over a decade.
    2. In the Cerrado biome, a study by Agrosatelite based on geospatial data between 2014 and 2017 found that only 7% of soybean expansion in the Cerrado occurred with deforestation, while 93% occurred in already open areas. With this, the soybean crop in the Cerrado reached, in 2017, the lowest deforestation rate of the last 16 years. This was mainly due to increased productivity, with intensification of crops in already converted areas. Nevertheless, ABIOVE and its associates are studying solutions to reduce and, as soon as possible, eliminate Cerrado deforestation associated directly with soy, reconciling production with environmental, economic and social interests. ABIOVE is supporting initiatives to implement payments for environmental services for soy growers that agree to conserve Cerrado at rates beyond law requirements.


  1. Data from unregistered areas presented in the document are overestimated and calculated based on assumptions, not on evidences.
    1. The calculation is based on a study published in August 2018, as described in footnote 3. Authors assumed 502 million hectares as registrable area and compared with the 322 million hectares that were supposedly registered until June 2018, after excluding 91 million hectares that showed some overlap area with indigenous reserves, national reserves and not designated public areas. It is known that the methodology adopted by the 2018 study to exclude these records was based on the assumption that any overlapping area, regardless of size, invalidates the record and, consequently, the CAR was entirely excluded. As a result, the calculated unregistered area was hypothetically estimated at 180 million hectares. The most recent CAR data show that by the end of August 2019 there were 498 million hectares registered in the SICAR base. This means a void of only 4 million hectares in relation to INCRA’s registered area, not 180 million hectares.
    2. ABIOVE reinforces the importance of the Rural Environmental Registry and recognizes that the efforts made by the Brazilian Forest Service to populate the largest database of environmental information on rural properties in the world do not match the unregistered areas data presented in the study. The Brazilian Forest Service, official organization in charge of CAR database, does not recognize the 180 million hectares figure as unregistered areas.


  1. Nevertheless, it is necessary to reinforce that Brazilian producers are taking CAR seriously, otherwise 500 million hectares would have not been uploaded on the database by August 2019. Each CAR (around 5 million units) must be evaluated and validated by federal and state authorities in order to check overlaps, missed information or even on-purpose wrong spatial coordinates provided by landowners. While federal and state authorities do not validate the CARs, companies sourcing products from producers will not block farmers based on information included in each CAR. Those landowners who have not provided accurate information in the CAR, before validation is proceeded, are not acting outside the law.


  1. Finally, ABIOVE points out that it received the demand from Mongabay just two hours before the closing of the article, so it could not go deeper into the methodology to answer the demand in more detail. The version shared with us, on the methodology box (page 7), has a broken link to access full description of the methodology. Even so, the entity noted that the municipalities identified with risk of deforestation, such as Sinop and Sorriso (MT) and Luiz Eduardo Magalhães (BA), for example, are those in which the soybean crop is already consolidated. In addition, as pointed out above, it is very questionable how those responsible for the document reached the percentage of unregistered area.



ABIOVE – Associação Brasileira das Indústrias de Óleos Vegetais (Brazilian Association of Vegetable Oil Industries) has, for 37 years, represented the companies that process oilseeds and produce meal, vegetable oils and biodiesel. Our member companies are among the country’s largest exporters, adding value to Brazil’s oilseed and grain chains and stimulating sustainable production practices.