From forests to markets: assessing emergent behaviours of the EUDR on smallholder palm oil producers

The new deforestation-free products regulation (EUDR) is driving significant change in agricultural commodities. From traceability requirements to deforestation-free production, this policy will force supply chains to adapt and ensure that products entering the EU market are free of deforestation. In the palm oil sector, the supply chains in producing countries will have structural difficulties in complying, especially with the most at-risk and primary suppliers, smallholders. At the same time, these supply chains are highly complex, adaptative and dynamic, leading to a lack of visibility and structural opaqueness that can prevent any action towards its implementation. This study highlights the barriers and opportunities of EUDR implementation in palm oil, while analysing emergent behaviour from smallholders and the use of technology to achieve timely compliance. The present study employs two theoretical frameworks to analyse the implementation of the policy requirements: the multi-tier supply chain (MTSC) and complex adaptative systems (CAS) theories that allow for a simplified perspective on the dynamics of the palm oil sector while acknowledging the complexity and dynamic nature of its supply chain. The research utilizes a qualitative case study approach, gathering empirical data through 16 semi- structured interviews to different agents of the palm oil sector in Malaysia and Indonesia, as well as 4 webinar and several documents and websites to triangulate data and analyse it using qualitative content analysis in NVivo. The results show that pre-existing and contextual barriers exist, like competing legalities, land and traceability issues and smallholders being poorly established in the system. However, emergent behaviours by smallholders and technology show possible trade-offs and spillovers that can enhance and compel fast adoption, like catalysing group certifications, tackling low-hanging fruit tech requirements and increasing collaboration and connectivity with the supply chain. Topics like blockage at the midstream level and data governance were also raised and signaled as future topics of analysis.