SE Asia’s smallholders struggling to meet EUDR: Interview with RECOFTC’s Martin Greijmans
Mongabay (29/12/2025) - Smallholders produce significant quantities of Vietnam’s coffee, Indonesia’s palm oil, and Thailand’s rubber exported into the EU. Yet under the bloc’s upcoming deforestation-free regulation (EUDR), industry experts say small-scale producers across Southeast Asia need more support to help prepare them to comply with the new rules.
The European Union Deforestation Regulation (EUDR) is set to take effect at the end of 2026, after EU lawmakers voted earlier this month to postpone its implementation for the second year in a row, citing technical concerns.
Its goal is to ensure that forest-linked products imported into the EU are deforestation-free by introducing mechanisms that enable companies trading seven commodities — cattle, cocoa, coffee, palm oil, rubber, soy and timber — to track their products’ origins throughout the entire supply chain.
While experts say increased oversight is a vital step to reduce the footprint of EU consumption on forests, others have warned that without appropriate support and governance mechanisms, the new rules could introduce inequities that harm small-scale producers.
Many smallholders lack the capacity and capital to comply with some aspects of the new regulations, for instance. This could see them sidelined in favor of bigger producers who can more easily adapt, according to Martin Greijmans, community enterprise program lead at RECOFTC, a Thailand-based community forest nonprofit.
Further complicating matters are limited resources to inform smallholders about how the regulations will affect their businesses, underscoring the need for greater efforts by governments and private companies to help smallholders adapt, he says.
“One shocking thing that I still come across is that many smallholders and small-scale companies still lack understanding of the EUDR’s mandatory nature,” Greijmans tells Mongabay. “They often mistake it for a voluntary certification.”
In an interview with Mongabay’s Carolyn Cowan, Martin Greijmans talks about the challenges facing smallholders in Southeast Asia as they prepare for the EUDR, the existing initiatives available to support them, and the need to “future-proof” small-scale producers as global sustainability requirements continue to evolve. The following interview has been lightly edited for length and clarity.
Mongabay: What are the current major gaps and challenges that smallholders in Southeast Asia face in complying with the EU Deforestation Regulation (EUDR)?
Martin Greijmans: There’s a lot of variability between countries, commodities and landscapes. In many instances, smallholders have demonstrated strong capacity to overcome some of the challenges of complying with the new regulations. But many smallholders, especially in remote areas or marginalized groups, lack clear land tenure or legal documentation. This makes it difficult for them to demonstrate legal production — an essential EUDR requirement — and could mean private sector traders might not be interested in buying from them because of these complications.
Smallholders often also struggle to collect the necessary geolocation data and digital documentation to comply with EUDR traceability requirements. Although some mapping efforts are underway, many smallholders still lack mapped land plots. For compliance with the EUDR, however, traders require this data. Therefore, they might send their staff to collect it using tools that are inaccessible to smallholders and their communities. This raises important questions about who owns the digital data collected, as it is not always shared equitably with farmers. It also remains unclear whether communities understand the data being generated and how they can benefit from it. Privacy concerns further complicate matters: who can access the data and how it is used.
This is why smallholders need support to help them participate in the data collection process. Some groups, like AGRIAC [a small-scale rubber support organization based in Thailand] are training smallholders on geolocation data requirements so they can understand where the data comes from, how to collect it, and how to manage it. But when it comes to private companies who are primarily focused on securing supply, they may not invest so much in empowering smallholders unless they have a specific social agenda.
Mongabay: Secure land tenure seems to be critical for smallholders to demonstrate legal production under the EUDR and also to access finance. Do you see certain groups of smallholders being especially at risk of losing out once the rules take effect?
Martin Greijmans: Ethnic minorities in remote, mountainous areas and those with unclear land tenure are the most at risk of being excluded. This includes widowed women in some countries. For example, in Laos, land legal documents typically only list male names.
There’s a risk that traders who want to secure their supply chain might start to avoid smallholders in circumstances where legality cannot be verified from land titles. From the company’s perspective, it might be too expensive to engage with them, risking being cut off from EU markets despite being responsible producers.
This could push already vulnerable smallholders toward non-EU markets with fewer regulations and lower environmental standards, or toward growing less sustainable crops like corn. Currently, there are no specific legal safeguards in place to protect these vulnerable groups against risks like land dispossession that might arise if they’re shut out of big markets, such as the EU.
Mongabay: What kind of support do smallholders need to help overcome these risks and support their capacity to meet the new requirements?
Martin Greijmans: Accelerating the legal registration of land for marginalized groups is crucial but costs money. Although progress is being made, such as in Indonesia through social forestry reforms, lack of funding often limits what can be achieved in many locations. It’s an expensive undertaking and might not reach remote communities quickly enough.
New technologies like drones could help. Drones are a very quick way of surveying plots of land and demonstrating to what extent boundaries overlap with forest areas. However, their official acceptance for legal documentation is uncertain, and flying a drone in countries like Vietnam is not simple.
Mobile apps can be helpful too. We have a project in Lam Dong province in Vietnam, part of the Reversing Environmental Degradation in Africa and Asia (REDAA) program, to help smallholder coffee farmers collect and manage their own data with a view to developing biodiversity-rich agroforestry models. They’re using an open-source mobile phone app called Epicollect, and also traditional paper logbooks, to monitor a simple framework of 10 indicators, such as water quality and soil biodiversity, on a quarterly basis. This gives them a record of their sustainability progress. This goes beyond the requirements of the EUDR specifically, but it can help to build trust between smallholders and the companies they supply, especially if they can demonstrate sustainability improvements. In the longer term, we aim for this to extend to agroforestry systems beyond just coffee.
Mongabay: How are Southeast Asian governments preparing for the EUDR? Are national policies or land-use data systems being strengthened to help smallholders comply?
Martin Greijmans: Governments in the region are preparing, but with varying approaches. Indonesia and Malaysia, big oil palm producers, initially expressed strong complaints about the EUDR. But national land-registration systems are slowly coming together, although they remain incomplete and might not reach more remote and marginalized areas where legality of land ownership is less straightforward.
Vietnam took quite a positive outlook to the EUDR, focusing on the coffee sector as they’re the second-largest coffee exporter in the world, and the EU is a significant market. They’re looking at it as an opportunity to have a competitive advantage in the coffee sector as a nation. Over the years, there have of course been issues in the coffee sector in Vietnam: a lot of forest degradation in the central highlands where robusta coffee is grown. Robusta doesn’t need tree cover like arabica. However, the government has been introducing new mechanisms, such as the Strategy for Sustainable Agriculture and Rural Development 2021-2030 (Vietnam), as well as encouraging international voluntary sustainability certifications (e.g., Rainforest Alliance, Fairtrade, 4C), demonstrating some progress toward sustainability, even before the EUDR came into view.
Vietnam has specific challenges because farmers don’t have the security of owning land. On paper, all land in Vietnam officially belongs to the state, with farmers holding temporary land-use certificates for 30 to 50 years. However, Vietnam’s Ministry of Agriculture and Rural Development got support from the Sustainable Trade Initiative (IDH) to develop a national database system for mapping forest and coffee-growing areas to support the traceability requirements of the EUDR. It hasn’t been completed yet, but the low-hanging fruit of the larger, legally straightforward plots have been documented.
Ultimately, support for meeting the compliance requirements varies from country to country based on whether the government views the commodities as an important economic incentive. The rubber sector is quite mature in Thailand, as are the palm oil sectors in Indonesia and Malaysia. But if you go to Laos, for instance, government rubber sector support is missing, so companies (which are mainly Chinese companies there) have more influence.
Mongabay: Beyond national-level efforts, what other types of initiatives or programs are helping smallholders prepare for the EUDR in Southeast Asia?
Martin Greijmans: Well, there’s been very little funding from the EU to do anything. GIZ [Germany’s Agency for International Cooperation] had an EUDR engagement project in five countries in Southeast Asia that had an element of focus on training smallholders to raise awareness of the EUDR, but that’s wrapping up at the end of 2025. It would be good to be able to scale up that work, to institutionalize these types of trainings into agencies like, say, the Rubber Authority of Thailand or the Roundtable on Sustainable Palm Oil.
One shocking thing that I still come across is that many smallholders and small-scale companies still lack understanding of the EUDR’s mandatory nature. They often mistake it for a voluntary certification like the Forest Stewardship Council (FSC) certification. But with so little funding around to get the word out, a lot of the outreach ends up being driven by the larger companies that buy from them or through the few outreach projects that are able to operate.
Mongabay: From the evidence you’ve seen in the field, are you hopeful that enough can be achieved to support smallholders as the compliance deadline approaches?
Martin Greijmans: Quite a few organizations are working hard to prepare smallholders for compliance through outreach and information sharing. AGRIAC in Thailand, for example, has reached out to RECOFTC to learn how to deliver more effective trainings. I think these types of organizations deserve far more support.
I also see signs that NGOs to trying to play a slightly different role in value chains than previously. It’s perhaps partly driven by funding cuts, but also they’re increasingly understanding companies’ requirements and building partnerships within value chains, rather than solely supporting farmers in isolation. Supply chains can be complex, with many intermediaries, so showcasing the capacity of smallholders to meet sustainability goals that go beyond even the EUDR requirements (as we’re trying to do with the data collection apps in Vietnam), underscores to companies why it makes sense to work with them.
Building trust within the value chain, between the farmers, farmer organizations and the private sector, is where I see NGOs having the most meaningful role right now. This ensures sustainable change beyond single project life cycles and timescales, and future-proofs smallholders. The EUDR will not be the last legislative change these sectors have to keep up with, so having those strong relationships there and building capacity means smallholders are more resilient and less likely to be left behind.