Europeaid/138778/Dh/Ser/Multi Siea 2018 Lot 1: Sustainable Management of Natural Resources and Resilience

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EuropeAid/138778/DH/SER/Multi SIEA 2018

LOT 1: SUSTAINABLE MANAGEMENT OF NATURAL RESOURCES AND RESILIENCE
Assessment of the potential impact of the

proposal for an EU regulation to prevent
deforestation-products originating from Thailand
to enter the EU Market
SPECIFIC CONTRACT 300054988
FINAL REPORT
D2 (OPSYS)
July 2023
This project is funded by the European Union A project implemented by Landell Mills International
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DISCLAIMER
The opinions expressed in this document represent the authors’ point of view, which are not
necessarily shared by the European Commission or by the authorities of the concerned
countries.
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Assessment of the potential impact of the proposal for

an EU regulation to prevent deforestation-products
originating from Thailand to enter the EU Market
DRAFT FINAL REPORT
July 2023
Prepared by:
David Gritten
Weeraphart Khunrattanasiri
Address:
Landell Mills International
The Old Station House
15a Main Street
Blackrock
Co. Dublin
Ireland
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KEY DATA
Framework Contract EuropeAid/138778/DH/SER/Multi Framework Services for the

Implementation of External Aid – Lot 1 Sustainable
Management of Natural Resources and Resilience
Specific contract number: Contract #300054988
Name of project: Assessment of the potential impact of the proposal for an EU

regulation to prevent deforestation-products originating from
Thailand to enter the EU Market
Start/end date: 15 January 2023 – 8 July 2024
Contracting Authority: Delegation of the European Union to Thailand
Task Manager: Saroj Srisai
Contractor: Landell Mills International
QUALITY ASSURANCE STATEMENT
FINAL REPORT
Version: DRAFT FOR DISSEMINATION
Prepared by: Name Position
David Gritten Team Leader
Weeraphart Khunrattanasiri Thailand-based expert
Checked by: David Gritten Team Leader
Matilde Anttila Project Executive, Landell Mills
Harriet Bull Manager, Framework Division, Landell Mills

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Table of Contents
EXECUTIVE SUMMARY 9
Background............................................................................................................................................... 9
Methodology ............................................................................................................................................. 9
Desk review 9
Interviews 9
Workshops 10
Findings................................................................................................................................................... 10
Opportunities and challenges 10
Potential impacts 11
Ways forward – potential cooperation and support measures ......................................................... 12
1. INTRODUCTION 13
2. METHODOLOGY 14
2.1. Assessment framework ............................................................................................................. 14
2.2. Desk review ................................................................................................................................. 14
2.3. Interviews .................................................................................................................................... 16
2.4. Workshops .................................................................................................................................. 18
2.5. Conference .................................................................................................................................. 18
2.6. Limitations................................................................................................................................... 18
3. FINDINGS 20
3.1. Context ........................................................................................................................................ 20
3.1.1. EUDR context 20
3.1.2. Thailand context 21
3.2. Challenges and opportunities for EUDR implementation in Thailand ................................. 33
3.2.1. Deforestation and degradation 33
3.2.2. Awareness of EUDR 35
3.2.3. Due diligence, including chain of custody (CoC) 39
3.2.4. Capacities 44
3.2.5. Governance, legal frameworks, and other relevant initiatives 46
3.2.6. Definitions 50
3.3. Potential impacts of the proposed Regulation in Thailand ................................................... 52
3.3.1. Potential Impacts - Addressing deforestation and degradation in Thailand 52
3.3.2. Potential impacts - Smallholders 52
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3.3.3. Potential impacts - SMEs 54

3.3.4. Possible impacts of benchmarking 55
3.3.5. Potential impacts of ending VPA process 56
3.3.6. Other potential impacts 56
4. WAYS FORWARD 58
4.1. Stakeholder analysis .................................................................................................................. 58
4.2. Potential cooperation approaches and support measures and activities ........................... 60
4.2.1. Approaches and support measures that can be facilitated or led by the EU agencies 60
4.2.2. Suggested priority actions for RTG agencies 65
ANNEXES 68
Annex 1. Forest area in Thailand during the period 1973-2020 ........................................................ 68
Annex 2. Enforcement actions by DMCR and DNP in recent years ................................................. 69
Annex 3. Forest loss and reforestation in Thailand for period 2018-2020 and 2021-2022 ............. 71
Annex 4. State forests and responsible government agencies ........................................................ 72
Annex 5. Additional data on agricultural production in Thailand ..................................................... 73
Annex 6. Thailand’s imports and exports of EUDR relevant commodities 2019-2021 ................... 76
Annex 7. Overview of production of EUDR relevant commodities in Thailand .............................. 80
7.1 Cattle 80
7.2 Cocoa 83
7.3 Coffee 84
7.4 Palm oil 87
7.5 Soya 91
7.6 Rubber 93
7.7. Wood 96
Annex 8. Production of cassava, maize and sugar cane in Thailand............................................. 103
8.1 Cassava 103
8.2 Maize 104
8.3 Sugar cane 105
Annex 9. Standards and certification schemes used in Thailand that are recognised by RTG .. 106
Annex 10. Defining SMEs .................................................................................................................... 116
10.1 Defining SMEs in Thailand 116
10.2 Defining SMEs in the EU 117
Annex 11. Notes from interviews conducted as part of the assignment ....................................... 118
LIST OF FIGURES
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Figure 1 Assessment framework for the assignment............................................................................... 14

Figure 2 Forest area in Thailand in 2022 ................................................................................................. 21
Figure 3 Forest area (%) in Thailand during the period 1973 – 2022...................................................... 23
Figure 4 a and b. Forest changes in Thailand during 2018 – 2020 ......................................................... 24
Figure 5 a and b. Forest changes in Thailand during 2021 – 2022 ......................................................... 25
Figure 6 a – d Distribution of the cultivated areas of rubber, palm oil, coffee and soya .......................... 30
LIST OF TABLES
Table 1 Overview of the stakeholders interviewed for the assessment .................................................. 17

Table 2 Change in area for different forest types during the period 2000-2018...................................... 23
Table 3 Number of fire hotspots in each region (2022) ........................................................................... 26
Table 4 Forest area under DNP management affected by fires (2014-2022) ........................................ 26
Table 5 Area and estimated number of households planting economic Crops in NRF in 2020 ............. 27
Table 6 Number of villages and people living in protected areas (2020) ................................................ 27
Table 7 Area under cultivation by smallholders for selected EUDR related commodities ...................... 29
Table 8 Area under smallholder management and number of smallholders for EUDR relevant
commodities ............................................................................................................................................. 31
Table 9 Number of agribusiness SMEs that are part of the supply chains for the seven commodities in
Thailand in 2021 ....................................................................................................................................... 31
Table 10 Value of Thailand’s exports of major agricultural products during 2017-2021 ......................... 32
Table 11 Overall Trade between Thailand and EU.................................................................................. 32
Table 12 Value of Thailand’s exports of EUDR commodities to the EU in 2022 ..................................... 33
Table 13 Overview of the challenges and opportunities for EUDR implementation regarding addressing
deforestation and degradation raised by stakeholders in the workshops and interviews ...................... 34
Table 14 Overview of the challenges and opportunities for EUDR implementation regarding awareness
of the Regulation raised by stakeholders in the workshops and interviews ............................................ 35
Table 15 . Overview of the challenges and opportunities for EUDR implementation regarding due
diligence systems raised by stakeholders in the workshops and interviews ........................................... 40
Table 16 Overview of the challenges and opportunities for EUDR implementation regarding capacities
raised by stakeholders in the workshops and interviews ......................................................................... 45
Table 17 Overview of the challenges and opportunities for EUDR implementation regarding governance,
legal frameworks and national initiatives raised by stakeholders in the workshops and interviews ....... 46
Table 18 Impact analysis of EUDR on Non-State Actors ........................................................................ 58
Table 19 EUDR commodity related government organisations and their main responsibilities in context
of EUDR ................................................................................................................................................... 59
Table 20 Proposed activities as part of awareness raising campaign ..................................................... 61
Table 21 Proposed activities as part of capacity development program ................................................. 63
Table 22 Proposed activities to foster partnerships and collaboration .................................................... 64
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ACRONYMS
AMAF ASEAN Ministers on Agriculture and Forestry

AMS ASEAN Member States
ASEAN Association of Southeast Asian Nations
ASEAN FPD ASEAN Experts Group on Forest Products Development
ASEAN WEN ASEAN Wildlife Enforcement Network
ASOF ASEAN Senior Officials Meeting on Forestry
ASW ASEAN Single Window
AWG-SF ASEAN Working Group on Social Forestry
BCG Bio-Circular Green Economic Model
CA Competent authority
CBAM Carbon Border Adjustment Mechanism (EU)
CF Community forestry
CoC Chain of Custody
COVID-19 Coronavirus Disease 2019
CSO Civil society organisation
DD Due diligence
DDS Due diligence system
DFT Department of Foreign Trade, Thailand
DLD Department of Livestock Development, Thailand
DMCR Department of Marine and Coastal Resources, Thailand
DNP Department of National Parks, Wildlife and Plant Conservation, Thailand
DTN Department of Trade Negotiations, Thailand
EC European Commission
EFI European Forest Institute
EIA Environmental Investigation Agency
EU European Union
EU-ABC EU-ASEAN Business Council
EU-CSDDD EU Corporate Sustainability Due Diligence Directive
EUD EU Delegation (in Thailand)
EUDR EU Deforestation Regulation (also known as Regulation of the European Parliament and
of the Council on the making available on the Union market as well as export from the
Union of certain commodities and products associated with deforestation and forest
degradation and repealing Regulation (EU) No 995/2010)
EU MS EU Member States
EUTR European Union Timber Regulation
FAO Food and Agriculture Organization
FIO Forest Industry Organisation, Thailand
FLEGT Forest Law Enforcement, Governance and Trade
FPP Forest Peoples Programme
FSC Forest Stewardship Council
FTI Federation of Thai Industries
GAP-CC Implementation Agreement for ASEAN-German Programme on Response to Climate
Change: Agriculture, Forestry and Related Sectors
GFW Global Forest Watch
GIA Green Invest Asia
GIS Geographic information system
GPSNR Global Platform for Sustainable Natural Rubber
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HS Harmonised Commodity Description and Coding System

IMPECT Inter Mountain Peoples Education and Culture in Thailand Association
IPLCs Indigenous Peoples and local communities
IUCN International Union for Conservation of Nature
ITTO International Tropical Timber Organization
LM Landell Mills
MEL Monitoring, evaluation and learning
MOAC Ministry of Agriculture and Cooperatives, Thailand
MNRE Ministry of Natural Resources and Environment, Thailand
NCPO National Council for Peace and Order, Thailand
NRF National Reserved Forest
NSA Non-state actor
OAE Office of Agricultural Economics, Thailand
OECD The Organisation for Economic Co-operation and Development
OIE Office of Industrial Economics, Thailand
OSMEP Office of Small and Medium Enterprise Promotion, Thailand
PEFC Programme for the Endorsement of Forest Certification
PFPC Private Forest Plantation Cooperative Limited
RAOT Rubber Authority of Thailand
RECOFTC Regional Community Forestry Training Center for Asia and the Pacific
RED2 Renewable Energy Directive
RFD Royal Forest Department, Thailand
RSPO Roundtable on Sustainable Palm Oil
RTG Royal Thai Government
RTRS Round Table on Responsible Soy
RO Regional Office
SA State Actor
SMEs Micro, small and medium sized enterprises
SPOTT Sustainable Palm Oil, Timber and Rubber Platform
TACFS Thai Agricultural Commodity and Food Standard
TAS Thai Agricultural Standard
TIS Thai Industrial Standard
TEFSO Thai-EU FLEGT Secretariat Office
TFCC Thailand Forest Certification Council
TICA Thailand International Cooperation Agency
TLAS Timber Legality Assurance System
TSPOA Thailand Sustainable Palm Oil Alliance
ToR Terms of Reference
UN United Nations
VPA Voluntary Partnership Agreement
VSS Voluntary Sustainability Standards
WTO World Trade Organisation
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EXECUTIVE SUMMARY
Background
The European Union’s (EU) Regulation on deforestation-free supply chains, the EUDR, came into force on 29
June 2023, with the main obligations due to apply to most companies from 30 December 2024 onwards, with small
and medium sized enterprises (SMEs) having to comply from 30 June 2025. The Regulation covers seven
commodities - cattle, cocoa, coffee, palm oil, rubber, soya, and wood - and their derived products. The Regulation
effectively means that operators and traders will have to prove that the traded products are deforestation free -
produced on land that was not subject to deforestation (or degradation for wood) after 31st December 2020 and
compliant with all the relevant laws in the country of production. The implementation of the EUDR is centred on
mandatory due diligence, with strict traceability for the commodities.
This innovative Regulation could have significant impacts on the protection of forests around the world. The EU,
however, acknowledges the risks associated with such a regulation, including for smallholders and SMEs in the
producer countries. Recognising these risks, the EU Delegation (EUD) in Thailand has commissioned an
“Assessment of the potential impact of the proposal for an EU regulation to prevent deforestation and forest
degradation on products originating from Thailand that are placed on the EU market.” Specifically, the assessment
includes assessing the possible effects of the proposed EUDR on those involved in the supply chains for the
relevant commodities in Thailand, in particular on smallholders and SMEs. The work also examines the readiness
of Thai industry, The Royal Thai Government (RTG) and farmers to facilitate compliance with the Regulation and
the need for a more comprehensive cooperation approach, covering all relevant commodities and the
deforestation-free elements beyond legality. One output of the work will include potential options for continued EU
support, building upon the positive aspects of the Forest Law Enforcement, Governance and Trade Voluntary
Partnership Agreement (FLEGT VPA) negotiations, in particular policy and regulatory reforms and broad
stakeholder engagement, including with smallholders.
A team, facilitated by Landell Mills (LM), has been tasked with conducting the assessment.
Methodology
The assessment is based on the following methodology:
Desk review
The desk review covered the following overlapping areas:
i. Due diligence analysis

ii. Forest and land use data and mapping
iii. Legal analysis
iv. Stakeholder analysis
v. Supply chain analysis
vi. Trade data analysis
Interviews
Interviews were held with representatives of various stakeholder groups during the period 9th February to 7th March
2023. In total 63 individuals from 40 organisations and smallholders were interviewed. Some individuals
represented more than one organisation.
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Workshops
The research team also joined three workshops that examined Thailand’s readiness for the EUDR. Two of the
workshops were hosted by Kasetsart University and had representatives from government and non-government
organisations. The third workshop was an internal workshop organised by the Regional Community Forestry
Training Center for Asia and the Pacific (RECOFTC) which explored the potential impact of the EUDR in Southeast
Asia, including Thailand.
Findings
Opportunities and challenges

The situation regarding deforestation and degradation in Thailand are improving, with the forest area in the country
remaining consistent for the last 10 years or so – around 31.6%. Nevertheless, forests are still facing significant
pressures reflected in the forest loss of 49,102 ha during the period January to March 2021 to January to March
2022, compared to over 350,000 ha a year during the period 1973 to 1998. The progress reflects the significant
efforts made by the RTG, with support from partners. The work of the RTG has included strengthening the legal
framework, though work is still to be done, particularly for addressing rights of local communities. The Voluntary
Partnership Agreement (VPA) has also helped, not only through the development of systems e.g., the Thai Timber
Legality Assurance System (TLAS), but also improved governance, including through capacity development for
civil society. Thailand does, however, have a sizeable deforestation risk on its imports of commodities – including
US$3.2 billion of soya imported from Brazil in 2022, as well as a large amount of non-EUDR deforestation risk
commodities such as cassava and maize imported from neighbouring countries.
Awareness and communication gaps regarding the EUDR were a pressing concern for most of those interviewed.
These gaps framed many of the responses in the interviews, including the potential impacts of the Regulation.
While the RTG, and civil society, have started to raise awareness, including through technical workshops, as well
as outreach to smallholders through television and radio, many key stakeholders have substantial questions and
misunderstandings of many of the EUDR’s fundamentals. This is particularly concerning considering the tight
timetable.
Meeting due diligence requirements will be challenging for many, if not all the supply chains if urgent action is not
taken. While the TLAS for wood is well developed, a few issues still need to be addressed (e.g., import controls).
The traceability for the other supply chains is generally far less developed – for example, for rubber from
landholding to mill is often lacking. Rubber, palm oil and wood have ambitious programs for certification, however,
from a low starting point. Some expectations, mixed with hope, among those interviewed are that certification
schemes (e.g., Programme for the Endorsement of Forest Certification (PEFC) and Forest Stewardship Council
(FSC) for rubber and wood, Roundtable on Sustainable Palm Oil (RSPO) for palm oil) would completely align with
EUDR. However, there is limited uptake of certification among smallholders – due to high costs, and limited
benefits, as well as other barriers. The challenges for smallholders getting certification are thought to be relevant
for them to meet EUDR requirements. Furthermore, a few respondents noted that some supply chain actors will
push back against transparency required for EUDR – particularly intermediaries (often referred to as middlemen).
Numerous capacity gaps exist among actors in all the supply chains analysed. While many state and non-state
actors such as the Rubber Authority of Thailand (RAOT) and civil society organisations (CSOs), are working to
address these gaps, some issues are more systematic than others.
Compliance with relevant legislation was not flagged as a large concern – except for land use rights. The RTG
has made significant efforts, but work needs to be done addressing rights of those living in National Reserved
Forest (NRF) – estimated that 2.1 million ha of plantations in NRF, of which 1.1 million ha are EUDR relevant
commodities.
There are various national and international initiatives that may support EUDR. This includes the National Strategy
(2018-37), which contains a commitment to having traceability in supply chains “to reduce forest encroachment
and deforestation”. In addition, the national forest area target of 40% by 2037, the One Map Project, the e-Farm
system, and National Single Window System for increasing efficiency for trade among others will provide
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significant opportunities. Furthermore, the RTG’s desire to conclude Free Trade Agreement (FTA) with EU may
help motivate its support for EUDR.
Data availability is broadly a strength – including for the level of detail in digital maps. However, there are some
key data gaps, related to data collection (e.g., for measuring degradation), but also management with some data
not being complete due to apparent territoriality between government agencies. The challenges on this may
undermine efforts to identify the risks from EUDR’s implementation, and to measure its impact, but also other
related initiatives.
Potential impacts
In 2022 Thailand exported approximately US$1.83 billion of EUDR commodities to the EU, of which rubber is by
far the largest share (US$1.7 billion, 11.5% of Thailand’s total rubber exports), followed by wood (US$70.2 million,
1.4%), cattle (US$4.3 million, 0.7%), oil palm (US$19.1 million, 1.3%) and cocoa (US$2.9 million, 4.2%). Coffee
and soya exports were both well under US$500,000 (9% and <0.1% respectively). Thailand’s total exports of the
EUDR commodities to the EU are roughly half that of its exports to other AMS, and less than 10% to the world as
a whole.
As mentioned above, Thailand is being increasingly effective in addressing deforestation and degradation, though
challenges persist. It is thought that little deforestation in the country is linked to EUDR commodities. In this context
many interviewees questioned the value of the EUDR for Thailand, particularly as they are worried about costs.
However, some recognised the need for Thailand to minimise its deforestation footprint beyond its borders and
recognised the challenges in doing so, feeling that the EUDR can support these efforts. Additionally challenges
on data availability, including to understand the specific causes of forest loss and degradation, also highlight the
possible value of the EUDR in supporting traceability, including transparency.
Smallholders are often struggling to make a sustainable income from their land. The RTG and civil society, as well
as the private sector, are supporting livelihood diversification programs for farmers to help address this. The
concern is that the EUDR will place even more burdens on farmers, specifically that they will have to bear the
costs for meeting the EUDR, and that these costs and will be prohibitive for some. The struggles for many
smallholders may be increased as companies focus on working with certain smallholders – those with better
access to services, and part of supply chains with fewer intermediaries. The worry is that smallholders in remote
areas may be excluded, and therefore have reduced income from commodities and may have to rely on forests to
supplement their livelihoods. This needs to be considered in the context that smallholders are fundamental for
many EUDR commodity supply chains in Thailand – there are approximately 1.7 million rubber and 364,000 palm
oil smallholders, with 4 million ha and 1 million ha of plantations, respectively.
While the main concerns raised were regarding smallholders, there was also concern about implications for SMEs
in Thailand, and that they may struggle to bear additional costs from EUDR compliance. A few interviewees
suggested that increased transparency from the EUDR may help to better understand roles and capacities of
actors in supply chain, including SMEs (e.g., intermediaries), but also result in some being removed from supply
chains. Like smallholders, SMEs play a key role in commodity supply chains – there are nearly 137,000 SMEs
registered as being part of those for EUDR commodities, though data on those that are involved in supply chains
to the EU is not collected.
Unease was also apparent that companies may be encouraged to focus on countries that have 1) better due
diligence systems (DDS) in place and 2) have few deforestation and degradation challenges. This reflects the
difficulties they may face with competent authorities and meeting all DDS requirements. This could lead to the
weaker countries having fewer market opportunities. The general feeling was that Thailand was well placed on
this, but also need to recognise that Thailand imports a great deal of EUDR commodities from potentially high-risk
countries.
The respondents almost universally raised the need for the EU to synergise with the various national, regional
(including ASEAN), and international initiatives, including recognising failure to do so will threaten the EUDR’s
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implementation. Those from civil society also emphasised the need for the EU to provide continued support to
address governance issues, building on the VPA.
Ways forward – potential cooperation and support measures

Based on the aim of the EUDR, and the findings from the interviews and desk work, interventions should be
designed and implemented to have the following broad objectives:
1. Increase legal and deforestation-free trade flows

2. Reduce deforestation and forest degradation in Thailand
3. Strengthen forest governance, with emphasis on rights and participation of Indigenous Peoples and
Local Communities (IPLCs)
4. Increase the effectiveness of cooperation and policy/political dialogue between the EU and Thailand.
5. Minimise risks and negative impacts resulting from EUDR’s implementation
6. Build on existing initiatives that could be integrated in regulation more comprehensive approach
It is suggested that EU agencies would help to achieve these through:
1. Awareness raising campaign:

a. National and sub-national EUDR workshops
b. Creation of national EUDR communication strategy and plan
c. Development and dissemination of appropriate communication materials for key stakeholders
to raise awareness of the EUDR
d. Public awareness campaign
e. Study tour
2. Development and implementation of a capacity development program:
a. Capacity development needs assessment (CDNA)
b. Capacity development program for RTG agencies
c. Capacity development program for NGOs
d. Capacity development program for farmer associations
3. Partnership development and collaboration:
a. Clarify next steps for the VPA negotiations
b. Establish monitoring system for measuring the impact of the EUDR and other related
mechanisms
c. Synergise with other initiatives, including regulations in EU, EU MS and other countries, as
well as ASEAN levels.
Suggested priority actions for the RTG include:

1. Creation of EUDR national focal point.
2. Clarification of plan for implementation of the traceability system proposed in the National Strategy
2018-2037
3. Creation of a national portal supporting traceability and transparency for the relevant commodities
4. Improve data management across RTG ministries and departments to better prepare for EUDR and
help understand its impacts.
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1. INTRODUCTION
The European Union has recently finalised a new Regulation on addressing trade in forest risk commodities –
specifically “on the making available on the Union market as well as export from the Union of certain commodities
and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010”.
The Regulation, the EUDR, covers seven commodities - cattle, cocoa, coffee, palm oil, rubber, soya and wood,
and their derived products. The Regulation requires operators and traders to prove that the products are 1)
deforestation free – produced on land that was not subject to deforestation (or degradation for wood) after 31st
December 2020 and 2) compliant with all the relevant laws in the country of production, when they import them
into the EU. The implementation of the EUDR is centred on mandatory due diligence, with strict traceability for the
seven commodities. The Regulation, which came into force on 29 June 2023 provides a grace period for large and
medium-sized companies of 18 months (i.e. 30 December 2024), and 24 months for micro, small and medium-
sized enterprises (SMEs) (i.e. 30 June 202)1.
This innovative Regulation could have far-reaching impacts in efforts to protect forests around the world. The EU,
however, acknowledges the risks associated with such a regulation, including for smallholders and SMEs in
producer countries, and is considering scaling up its partnership approach to support the implementation of the
Regulation. Recognising these risks, the EU Delegation (EUD) in Thailand has commissioned an “Assessment of
the potential impact of the proposal for an EU regulation to prevent deforestation and forest degradation on
products originating from Thailand that are placed on the EU market.” Specifically, the assessment has the
following objectives:
1. Conduct an ex-ante assessment of the possible effects of the proposed EU Regulation on the relevant
commodities in Thailand (wood, rubber, palm oil and, potentially, other commodities in the scope), what
the impact of the Regulation could be in Thailand, in particular on smallholders and local communities, the
readiness of Thai industry, government and farmers to facilitate compliance with the Regulation and the
need for a more comprehensive cooperation approach, covering all relevant commodities and the
deforestation-free elements beyond legality;
2. To discuss next steps of partnership. The mission will list potential options for continued EU support,
building upon the positive aspects of the VPA experience, in particular policy and regulatory reforms and
broad stakeholder engagement, including smallholders.
A team, facilitated by Landell Mills, has been tasked with conducting the assessment. This report presents the
findings of the work. The report includes methodology (Section 3) and findings providing overview of challenges
and opportunities, as well as potential impacts (Section 4), and suggested ways forward (Section 5).
1
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CONSIL:ST_16298_2022_INIT&from=EN
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2. METHODOLOGY
2.1. Assessment framework
Based on the objectives of assignment a framework was developed to cover the following areas:
1. Potential effects of the proposed Regulation in Thailand, building on the Impact Assessment conducted in
preparation of the new legislative proposal.
2. Additional information that would facilitate further bilateral dialogue and help the design of support
measures.
3. Assess the need and the potential features of a more comprehensive cooperation approach, covering all
relevant commodities and the deforestation-free elements (beyond legality) and pre-identify potential
support measures.
The framework (Figure 1) provided the basis for the desk review and interviews, as well as guiding the structure
of this report.
Figure 1 Assessment framework for the assignment
2.2. Desk review
The desk review covered the following overlapping areas (alphabetical order):
i. Due diligence analysis

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iii. Legal analysis

i. Due diligence analyses

The objective of the analyses here was to understand the due diligence requirements in the Regulation for the
commodities, and the due diligence systems currently in place in Thailand, including those developed as part of
the Forest Law Enforcement, Governance and Trade (FLEGT) Voluntary Partnership Agreement (VPA)
negotiations, as well as those for various chain of custody requirements for the numerous voluntary certification
schemes, and those used by companies.
The due diligence analysis covered:
• Challenges and opportunities in ensuring due diligence is practical along the entire supply chains,
identifying possible challenges and opportunities, including for smallholders and SMEs.
• How Thai authorities and companies currently conduct due diligence (and chain of custody) along these
supply chains, and monitor the supply chain of the commodities, including determining source and verifying
legality including for imports.
• Identify learnings from the TLAS being developed under the VPA, including participatory processes and
implications for the EUDR.

The aims here were firstly to understand the resources in place to analyse forest change in the country, including
their ability to help identify forest conversion and degradation and its purposes, and secondly to conduct an
analysis using the available tools and data to identify all forest conversion and degradation since 31st December
2020, and again identify the purposes. Forest area data stored in geographic information system (GIS) were used
to help this analysis since the cut-off date of 31st December 2020 (i.e., 2021 and 2022) and for changes in the
years prior to the cut-off date.
The forest and land use data analysis covered:
• Analysis of the data and tools for monitoring forest conversion and identifying the needs to support the
monitoring to identify forest clearance and degradation since 31st December 2020, and conversion for the
growth of the commodities.
• Availability of data on and maps of land held by smallholders and communities, for each of the
commodities, with particular focus on cattle, palm oil, rubber, and wood.
• Analysis also attempted to identify conversion for other purposes beyond the seven commodities.
iii. Legal analyses

An analysis of the legal frameworks in Thailand was conducted to identify challenges and opportunities regarding
the EUDR. The legal analysis included:
• Definition of forest in Thai law, including canopy cover, and if rubber and palm oil plantations would be
considered as forest.
• Definition of SMEs Thailand.
• Requirements Thai laws have regarding due diligence for commodities, and how these compare with the
EUDR.
• Thai definitions of deforestation and forest degradation.
The assessment also considered government programs that can either facilitate or impede the implementation of
the EUDR in Thailand.

The desk review also involved a stakeholder analysis to identify the main actors involved in each of the supply
chains, to explore the potential impact of the EUDR on the different actors and their ability to support and/or hinder
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the EUDR’s success. This helped to propose ways forward for the EU to achieve its objectives for the EUDR in
Thailand.

Another key pillar of the work was the supply chain analysis for all the relevant commodities. The aim of the
analysis was to better understand the actors in each chain, their roles and responsibilities, and the potential
impacts of the Regulation.
The supply chain analysis covered:
• Agricultural production data for the commodities from RTG database including the Office of Agricultural
Economics (OAE). This helped to understand the value of the products, as well as the actors in the supply
chains.
• The analysis for each supply chain started from the land on which the commodity is produced to the point
of export from Thailand and import into the EU. This covered, but was not limited to, producers, processors,
plantation holders, farmers, smallholders, companies, and government. While information is provided for
each EUDR commodity. Consideration was given to the rights of the smallholders and their roles and
numbers, as well as SMEs in each of the supply chains.
• The data analysis also considered the role of certification for each commodity, for example the share of
the products that are certified as sustainable, as well as the links between these certification schemes and
the requirement of the EUDR.

The objective here was to understand the value of Thailand’s trade to the EU for the relevant commodities. This
helped to set the scene for the assignment. A key data source was the Thailand Trading Report System managed
by the Information Technology and Communication Center, Office of the Permanent Secretary for Ministry of
Commerce and Customs Department, Ministry of Finance. Other data sources were also used for the assignment,
including United Nations (UN) Comtrade and the ASEAN Stats Data Portal.
The trade data analysis covered:
• The value of Thailand’s total exports for each of the EUDR commodities to the EU. The data was sourced
from Thailand Trading Report System. The trade analysis used the relevant Harmonised Commodity
Description and Coding System (HS) codes as set out in Annex 1 of the Regulation.
• Using UN Comtrade data, analysis was done on the imports of EUDR and non-EUDR commodities to
Thailand from neighbouring countries (e.g., Cambodia, Lao PDR and Myanmar) and high deforestation
risk countries (e.g., Brazil).
vii. Literature review

A general literature review was also conducted to complement the above analyses, this covered:
• Existence of due diligence systems required for each commodity.

• Capacity needs assessment for supply chain actors to meet the DD requirements.
• Implications of the EUDR not including internationally recognised rights of Indigenous Peoples and local
communities, instead relying on national laws which, in the case of Thailand, are seen by some as being
weak.
• Partnership arrangements covering the EU and Thailand, including those linked to the VPA negotiations.
2.3. Interviews
The research team consulted various sources to enrichen the initial extensive list of proposed informants shared
by the EUD in the Terms of Reference (ToR) for this assessment. This includes from the database of the Office of
the Permanent Secretary for Ministry of Commerce and Customs Department, Ministry of Finance, as well as
databases of the expert team. The EUD reviewed the longlist and supported the research team to create a shortlist.
The process of moving from a long to a short list included identifying those that are best placed to address the
17
objectives of the assessment, including to improve understanding of the four main supply chains. Additional
potential interviewees were also identified throughout the assignment.
The EUD sent the initial invitation letters on 2nd of February 2023, with the assessment team following up through
email or phone to schedule the interviews. The interviews were held face-to-face where possible. If key informants
were not available for in-person interview, then the interview was held online.
Once the key informants agreed to the interview, the research team then shared more details of the work –
including the latest version of the EUDR, as well as the objectives and broad questions to be addressed to ensure
they were suitably prepared, and finally information on how the data that the interviewee shared would be used.
The interviews were held between 9th February and 7th March 2023. The interviews lasted between 45 and 90
minutes, some of the interviews lasted beyond 90 minutes. In some cases, an additional interview was arranged,
or follow up questions were shared by email.
In total 63 individuals from 40 organisations were interviewed (Table 1 provides an overview of those interviewed).
Some individuals represented an organisation, such as a farmer association, and were also smallholders.
Table 1 Overview of the stakeholders interviewed for the assessment
Stakeholder group Organisation # Individuals
Government Department of Foreign Trade (DFT) 2

Department of National Parks, Wildlife and Plant Conservation (DNP) 1
Department of Marine Coastal and Resources (DMCR) 1
Department of Trade Negotiations (DTN) 2
Federation of Thai Industries (FTI) 9
Forest Industry Organisation (FIO) 2
Office of Agricultural Economics (OAE) 2
Royal Forest Department (RFD) 2
Rubber Authority of Thailand (RAOT) 1
THAI-EU FLEGT Secretariat Office (TEFSO) 1
International EU Delegation (EUD), Thailand 1
governmental
Food and Agriculture Association (FAO) FLEGT (ex-consultant) 1
organisation
European Forest Institute (EFI), International Partnerships Facility, Kuala
1
Lumpur
EFI, International Partnerships Facility, Thailand (Th) 1
FAO Regional Office (RO) for Asia and the Pacific (RAP), Bangkok 1
EU DG Environment 1
International NGO EU-ASEAN Business Council (EU-ABC) 2
RECOFTC Regional Office 2
Fern 1
Global Platform for Sustainable Natural Rubber (GPSNR) 1
Green Invest Asia (GIA) 2

World Wide Fund for Nature (WWF) Belgium 1
National NGO Fast Growing Tree Business Association (FGTBA) 4
RECOFTC Thailand Office 3
18
Rubber Network Council

1
Rubber Farmers Institute of Thailand (RNRF) and rubber smallholder
Rubber Farmer Institute Network (RFIN) and rubber smallholder 1
Thailand Rubber Network

1
Rubber Plantation Farmer Association in Krabi Province & Rubber
smallholder
Thailand Wood Exporter Association (TWEA) 1
Krabi Farmer Council & Rubber and palm oil smallholder 1
Thai Hevea Wood Association 1
Thailand Environment Institute Foundation (TEI) 2
Thai Timber Association (TTA) 5

WWF Thailand 1
Private sector Private Forest Plantation Cooperative Limited (PFPC) 1

Plan Creation Co., Ltd. 1
Phang Nga Palm Oil Plantation Association 1
Smallholder Rubber Plantation Farmer 1
Smallholders that were also leaders of smallholder networks and
4
associations
2.4. Workshops
Three EUDR focused workshops were organised during the period of the assignment, the research team members
were invited to join as observers.
The Forest Research Centre, Faculty of Forestry, Kasetsart University hosted a half-day workshop on the “EU
Regulation on Deforestation Free Products: Opportunity, Impact and Readiness of Thailand” on 17 th February
2023. Preferred by Nature and AgriAc organised the second workshop, again at Kasetsart University on “New EU
deforestation regulation - Navigating the requirements” on 17th March 2023. Both workshops provided useful
information about the possible opportunities, impacts and readiness of Thailand regarding the EUDR, they also
highlighted the awareness gaps among many of the participants. Around 40 individuals including from government,
civil society, and the private sector joined the events in person, with many more joining online.
RECOFTC, an international NGO working on supporting rights of Indigenous Peoples and Local Communities in
the Asia-Pacific region organised a workshop for its country offices, including Thailand, on 8th February 2023. The
workshop was part of RECOFTC’s efforts to prepare its constituents – particularly smallholders, SMEs and CSOs
in Southeast Asia for the EUDR, and similar regulatory initiatives from other consumer and processor markets.
2.5. Conference
The findings of the study will be presented at a conference in Bangkok for key stakeholders. The event is expected
to take place on July 5th 2-4.30pm (ICT).
2.6. Limitations
The work for this assessment encountered a few challenges, with the main issue being that many of those
interviewed gave responses based on a limited understanding of the EUDR (see section 4.2.2 for the clarifications
19
sought by many of the interviewees). This lack of knowledge and understanding affected their consideration of the
potential impacts of the EUDR.
The availability of representatives from some stakeholder groups also proved to be a challenge. The most
challenging stakeholder group to access were the private sector. They were contacted through various means but
showed little interest to engage in the work. For example, it was possible to gather the names and contact details
of over 50 companies that are involved in supply chains of the various EUDR commodities to the EU, however,
these companies did not respond to the research team’s emails. It is clear that they would only respond to a formal
request from the appropriate government agency.
Additionally, staff from various government departments were made available for interviews, but it would have also
been of value to also get insights from relevant ministries – particularly the Ministry of Natural Resources and
Environment (MNRE) and the Ministry of Agriculture and Cooperatives (MOAC). This is important considering the
focus of the work of these level of agencies – broadly speaking the ministries being responsible for policy
development, and the departments focusing more on the technical policy implementation and enforcement area.
The relevant RTG agencies have been proactive in sharing relevant EUDR data and information, however, there
were some issues with data collection, including:
• Lack of detailed information on causes of forest loss and degradation. For example, it has not been
possible to access land use data that can be overlaid with forest cover change.
• Details on the number and role of SMEs in the commodity supply chains was not available.
• Lack of information on due diligence requirements applied by RTG on companies trading forest risk
commodities. Data is available for wood but is a challenge for the other commodities.
• There were also some inconsistencies in the data between government agencies.
Additionally, data from non-state actors has been hard to come by:
• Chain of custody systems used by companies for the various EUDR commodities.
• Prevalence of voluntary sustainability standards for the different commodities.
20
3. FINDINGS
3.1. Context
3.1.1. EUDR context

The EU’s push for the EUDR, which started in 2019 with the European Commission’s “Communication on Stepping
up EU Action to Protect and Restore the World’s Forests”, builds on various initiatives including the 2003 FLEGT
Action Plan and the 2020 Green Deal. The work of the EU in recent years demonstrates the bloc’s recognition of
the need to take further action to address deforestation and forest degradation, and the role it must play as both
a consumer of commodities linked to deforestation and a processor of these products for onward trade. The need
to move beyond the focus on timber legality, under the FLEGT Action Plan, to commodities and sustainability is
demonstrated by the fact that the expansion of agriculture is the main driver of deforestation – accounting for
roughly 88% according to FAO2. The need for the EU to act reflects that during the period 2008-2017 consumption
in the EU was responsible for 19% of tropical deforestation through the imports of beef, cocoa, coffee, palm oil,
soya and wood3.
The 2019 Communication further emphasised the importance of partnership for the success of any initiatives by
the EU to reduce its deforestation footprint – specifically “1) work in partnership with producer countries, to address
root causes of deforestation, and to promote sustainable forest management, and 2) international cooperation with
major consumer countries, to minimise leakage and to promote the adoption of similar measures to avoid products
coming from supply chains associated with deforestation and forest degradation being placed on the market.”4
The EU’s commitment to partnership again builds on previous efforts by the bloc, including directly through support
linked to the FLEGT VPA negotiations, including in Thailand5.
The draft EUDR has been broadly welcomed by many stakeholders, including NGOs in the EU (e.g., ClientEarth,
Environmental Investigation Agency (EIA) and International Union for Conservation of Nature (IUCN)) and by
some stakeholders in producer countries, including in Thailand (e.g., RECOFTC6). For example, ClientEarth
described it as a “...new gold standard for protecting forests. It has the potential to trigger the structural change
the world needs to finally turn the tide against global deforestation.7” However, these and many other stakeholders
have also expressed some reservations about the draft Regulation, including that its reliance on national legislation
rather than international agreements and guidelines on human rights, possible leakage resulting from the EUDR,
as well as challenges for companies, including SMEs, governments, as well as smallholders adhering to the
EUDR, when there are numerous overlapping regulations that may create burdensome complexities and costs.
Many NGOs have highlighted the short term need to raise awareness in producer countries as quickly as possible,
considering the short timetable for the Regulation to come into force. There is an understanding that some of these
concerns may not be addressed until a planned review of the Regulation in the next couple of years. Furthermore,
some governments in producer countries, including Indonesia and Malaysia have also expressed concerns, some
of them quite forcefully.
The EUDR needs to also be considered in the context of other legislation and initiatives in the EU (e.g., FLEGT
VPAs), and other consumer (e.g., UK Environment Act) and processing countries, as well as producer countries
(e.g., Thailand’s National Strategy 2018-2037 which includes emphasis on traceability in supply chains).
Additionally, voluntary sustainability standards, such as RSPO and PEFC may also impact the implementation
and enforcement of the EUDR.
2
https://www.fao.org/3/cb7449en/cb7449en.pdf
3
https://environment.ec.europa.eu/system/files/2021-11/SWD_2021_326_1_EN_impact_assessment_part1_v4.pdf
4
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52021PC0706
5
https://www.fao.org/in-action/eu-fao-flegt-programme/our-projects/zh/#/web/country/THA
6
https://www.recoftc.org/stories/what-eu-regulation-deforestation-free-products-means-communities-and-smallholders-asia
7
https://www.clientearth.org/latest/press-office/press/eu-deforestation-law-a-new-gold-standard-for-forest-
protection/#:~:text=The%20European%20Commission%20put%20forward,to%20deliver%20a%20strong%20law.
21
3.1.2. Thailand context
3.1.2.1 Thailand’s forests
Thailand’s location within two major biogeographical regions and its diverse landscapes, including rich forests,
make it one of the most biodiverse countries in Southeast Asia8, the country is home to many threatened species
that rely on forests and forest landscapes, including flagship species such as elephants (elephas maximus), and
tigers (Panthera tigris), as well as species that are endemic to the country9. Thailand’s forests are particularly
found in the north and west of the country (Figure 2).
Figure 2 Forest area in Thailand in 202210
It is estimated that over 12% of the Thai population live within a kilometre of a forest11, with many households
relying on forests for their well-being, especially in times of hardship. The importance of forests in the country is
further emphasised by the relatively large number of Indigenous People in the country – an estimated 6.1 million,
or approximately 9.7% of the total population12.
8
https://www.cbd.int/countries/profile/?country=th
9
https://animalia.bio/endemic-lists/country/endemic-animals-of-thailand
10
Forest Resources Survey and Analysis Division, Forest Land Management Office, Royal Forest Department
11
Newton, P., Kinzer, A. T., Miller, D. C., Oldekop, J. A., & Agrawal, A. (2020). The number and spatial distribution of forest-proximate people
globally. One Earth, 3(3), 363-370.
12
https://www.iwgia.org/en/thailand/4658-iw-2022-thailand.html
22
Thailand’s forests are important also from the point of view of climate change – adaptation and mitigation. It is
estimated that during the period 2006-2016 annual greenhouse gas (GHG) emissions from the forestry sector in
Thailand were 15,326,056 tCO2e, estimates of the annual GHG removals from the sector were -31,511,649
tCO2e13. Thailand has not included Land use, Land-use Change and Forestry (LULUCF) in their Nationally
Determined Contribution (NDC) to cut emissions and adapt to climate impacts.
Thailand has experienced significant impacts from the changing climate in recent years including the devastating
floods of 2011, this is reflected in Thailand ranking 9th in the 2021 Global Climate Risk Index14. The Index is based
on how countries have been affected by weather-related loss events during the period 2000-2019. However,
according to the World Bank, Thailand is thought to be well positioned in terms of vulnerability and readiness for
climate change compared with its Southeast Asian neighbours15. Nevertheless, river and coastal flooding could
affect millions in the coming decades, as well as threats of other extreme weather events highlight the importance
of the country’s ecosystems including for example mangrove forests in its protection, in addition to acting as a
safety net.
Over the last five decades or so the Thai economy has grown significantly, as the country has moved from being
a low-income to an upper middle-income country16. Thailand’s significant economic development, which saw its
Gross Domestic Product (GDP) grow from US$10.84 billion in 1973 to US$505.95 billion in 202117, has left a
significant imprint including on its natural environment. During the same period, the country’s forest area has
shrunk by over 26% (Figure 3, Annex 1). The change of forest area can be categorised into two periods: 1973-
1998 and 2000-2022 (Figure 2):
• Period 1: 1973 to 1998 (26 years): The forest area fell from 22,170,700 ha in 1973 to 12,972,200 ha in
1998. The average annual rate of loss during that period was 353,788 ha.
• Period 2: 2000 to 2022 (23 years): The forest area decreased from 17,011,078 ha in 2000 to 16,353,989
ha in 2022. The average annual rate of loss was 29,101 ha.
The two categories are based on the level of detail in the assessment of forest cover. During the first period (1973-
1998) satellite data used in the classification process was printed on paper, with a scale of 1:250,000. During the
second period (2000-2022) a higher resolution was available, with a scale of 1:50,000. The criteria used for
defining a forest did not change during the periods. The GIS techniques and automated processes were first
mainstreamed during the second phase. The use of different map scales and the transformation of the data
analysis methods from analogue to digital directly impacted the results hence the differences in the transition
between period 1 and 2. This of course has implications for the accuracy of the data, and how it can be used.
13
https://redd.unfccc.int/files/thailand_frel_frl_report.pdf
14
https://www.adaptation-undp.org/project/scala-thailand
15
https://climateknowledgeportal.worldbank.org/sites/default/files/2021-08/15853-WB_Thailand%20Country%20Profile-WEB_0.pdf
16
https://www.worldbank.org/en/country/thailand/overview
17
https://data.worldbank.org/indicator/NY.GDP.MKTP.CD?locations=TH
23
Figure 3 Forest area (%) in Thailand during the period 1973 – 202218
Table 2 provides a breakdown on forest area change according to the forest type. Note that accurate data is only
available for the years 2000 and 2018. However, estimates do exist for changes to some of the forest types prior
to 2000. For example, it is estimated that Thailand lost about 56% of its mangrove forests during the period 1961
to 199619. The data in table 2 also does not cover the impact of some national programs that started prior to 2000
– including the Government’s Farm Forestry Program (1994 - 2001) which was created in response to limited
wood supply. The programme provided subsidies for companies and smallholders for tree planting, with over
80,000 farmers joining the programme. The programme continued after 2001, but with significantly smaller
subsidies.
Table 2 Change in area for different forest types during the period 2000-2018
Forest types Area in 2000 Area in 2018 Area Change (+/- Area change (+/-
(1000ha)20 (1000ha)21 1000ha) %)
Bamboo forest 150.4 65.3 -85.1 -56.6
Beach forest 12.5 10.5 -2.0 -16
Dry dipterocarp forest 1,857.0 1,901.7 44.8 2.4
Forest plantations 347.7 150.9 -196.8 -56.6
Freshwater swamp forest 25.7 42.2 16.5 64.2
Evergreen forest 5,267.9 4,131.4 -1,136.5 -21.57
Mangrove forest 245.3 246.1 0.9 0.3
Mixed deciduous forest 8,744.5 7,551.1 -1,193.4 -13.65
Peat swamp forest 30.4 43.7 13.3 43.75
Pine forest 46.2 86.7 40.5 87.7
Secondary forest 283.7 288.9 5.3 1.8
Figure 4a shows the location of forest loss during the period 2018 – 202022, displayed in conjunction with fire
hotspot data (Figure 4b) derived from the Visible Infrared Imaging Radiometer Suite (VIIRS) aboard the Suomi
18
19
https://www.iucn.org/news/thailand/202005/thailand-celebrates-its-first-national-mangrove-forest-
day#:~:text=From%201961%20to%201996%2C%20Thailand,well%20as%20for%20their%20wood.
20
Source from Forest Statistics of Thailand 2002, Royal Forest Department.
21
Project of Thai Forest Area Classification 2018, Royal Forest Department.
22
Note that the data is collected each year during January to March or April
24
National Polar-orbiting Partnership (SNPP) satellite. The forest loss is mainly in the north and west of the country
in Chiang Mai, Mae Hong Son, Tak and Lampang provinces. The deforestation situation after the EUDR cut-off
date (January – March 2021 to January - March 2022) is shown in figure 5a – 49,101.785 ha of deforestation, with
more of the loss being in the northern provinces (23,506 ha or 47.9% of the total forest loss). During the period
nearly 37,000 ha of land was reforested, with 10,541 ha (28.6% of the total reforested area) of that being in the
northern provinces (see annex 3 for more details). The insets in Figures 4a and 5a are where there is the highest
level of forest clearance during the period 2020 to 2022 – in Mae Hong Son and Chiang Mai Provinces..
Figure 4 a and b. Forest changes in Thailand during 2018 – 2020 (4a, left), with hotspots for 2020 fire season (4b, right)23
23
Forest data in 2018 and 2020 from Forest Land Management Office, Royal Forest Department
Forest Fire Hotspot in 2020 from https://wildfire.forest.go.th/firemap/index.html
25
Figure 5 a and b. Forest changes in Thailand during 2021 – 2022 (5a, left), with hotspots for 2022 fire season (5b, right)24
According to the 13th National Economic and Social Development Plan (2022-2027) forest fires, both human and
natural made are the main cause of deforestation in recent years. The RTG does not, however, provide detailed
data on deforestation for conversion to agriculture, and does not have data on forest degradation in the country
and its causes. While those interviewed provided thoughts on the causes of forest loss and degradation, including
conversion for the EUDR commodities, specific data on this is not collected by RTG agencies.
Reflecting the 2022-2027 Plan the RTG is particularly concerned with forest fires, not only as they will increase
due to the climate change, but also the economic impacts of the resulting pollution that impacts on public health,
aviation, industry and tourism in the country. Smog and PM 2.5 crisis is not only caused by smoke from forest fires
but also caused by the smoke of open burning, weed burning from the agricultural sector. The Forest Fires Control
Divisions of the RFD and DNP currently work with remote sensing data to monitor the hotspots in the forest areas.
Data from VIIRS Suomi NPP, VIIRS from NOAA-20 and MODIS from Terra/Aqua are used and displayed in the
Active Fire Hotspot Database from Satellite Images by FIRMS25.
During the 2022 fire season (between 1st January to 31st May), according to the MODIS sensor onboard
Terra/Aqua satellite, Thailand experienced a total of 6,239 hotspots, most of which were in the north of the country
(Table 3). According to the DNP the fires affected 6,119 hectares of forest land under its management, lower than
previous years (Table 4).
24
Forest data in 2021 and 2022 from Forest Land Management Office, Royal Forest Department
Forest Fire Hotspot in 2022 from https://wildfire.forest.go.th/firemap/index.html
25
https://wildfire.forest.go.th/firemap/
26
Table 3 Number of fire hotspots in each region (2022) 26
Region Number of hotspots
Northeast 1,976
Upper north 1,907
Lower north 868
Eastern 541
Western 445
Central 425
Southern 77
Total 6,239
Table 4 Forest area under DNP management affected by fires (2014-2022) 27
Years Forest fire area (ha)
2014 8,116
2015 9,672
2016 20,015
2017 12,067
2018 8,923
2019 24,269
2020 27,970
2021 16,124
2022 6,119
The production of agricultural commodities in forests areas is an issue in Thailand. Under the National Reserved
Forests Act, B.E. 2507 (1964), the RFD has the power to declare an area to be a “national reserved forest to
maintain the conditions of plants in the forests or of other natural resources. Within the national reserved forests,
no person shall occupy, possess, exploit and inhabit the land, develop, clear, burn the forest, collect the forest
products nor cause by any other means whatsoever any damage to the nature of the national reserved forests”.
That means occupying or using land in NRFs for agriculture is illegal according to the 1964 law, with some
exceptions: 1) those whose occupation or use predates the demarcation of a particular area of NRFs and apply
for recognition within 90 days of land being designated forests, and 2) those granted concessions or other special
permission to use or reside on land. The area of Reserved Forests in Thailand covers 9,905,021 hectares (of a
total 16,353,989ha of forests).28
In 2020 the RFD investigated the crops planted within NRFs, finding that there were 8 crop types growing in these
forests with covering a total area of 2,153,721 hectares (i.e., 22.3% of the NRF area), with rubber comprising over
37% of the area (Table 5). Four of these crops are covered by the EUDR. While data is not collected on the number
of smallholders involved in growing these crops, it was possible to estimate the number, 771,943 households,
26
Summary Report on Forest Fires and Smog Situation Using Geoinformatics Technology in 2022, GISTDA
27
https://portal.dnp.go.th/Content/firednp?contentId=15705
28
https://forestinfo.forest.go.th/Content.aspx?id=10064
27
based on the national average cultivated area for individual smallholders of 2.79ha (see Annex 5, Table A9 for
more information).
Table 5 Area and estimated number of households planting economic Crops in NRF in 202029
Crops Area in hectares Estimated number of households

Rubber 809,419 290,114
Corn 480,676 172,285
Cassava 357,933 128,291
Sugarcane 200,025 71,694
Palm Oil 148,787 53,329
Teak 56,439 20,229
Eucalyptus 53,370 19,129
Pineapple 47,072 16,872
Total 2,153,721 771,943
The large area of crops grown in the NRF demonstrate that despite efforts by the RTG, including the National
Land Act (often known as Kor Thor Chor) and Community Forest Act, land rights are still a significant concern in
the country. In 2021 alone there were 1,893 cases of land encroachment found within the NRFs, covering an area
of 2,994 ha. In recent years, the RFD have agreed to 8,119 requests for land utilisation within NRF, covering
600,640 ha30. Of the 8,119 request 6,467 came from government agencies and remaining 1,652 from private
actors. 115 of these agreements cover palm oil and rubber plantations totalling 35,572ha31.
A substantial number of people are also living in protected areas in Thailand. Data from various government
agencies collated in Table 6 shows that over 316,000 people are living in and using nearly 684,000 ha of land in
protected areas.
Table 6 Number of villages and people living in protected areas (2020) 32
Details Number of Villages Number of people Number of land Area (ha)

parcels
National Park 2,780 205,016 299,670 408,947.65
Wildlife sanctuary 1,013 86,979 137,975 230,886.25
Non-hunting area 472 24,565 30,611 43,962.30
Total 4,265 316,560 468,256 683,796.20
Thailand has taken numerous steps to address deforestation and degradation; this includes introducing, in January
1989, a logging ban in natural forests. Nevertheless, logging and conversion of natural forests still occurs, though
at a reduced rate in recent years (as shown in Figure 3 and Annex 1).
The RTG has set a target forest area of 40% of the country33. Most recent data have the share as 31.57% (Figure
3). The efforts by Thai authorities to protect and restore its forests is demonstrated not only in the logging ban, but
also in other legislative developments including the revised Forest Act, National Park Act, Wildlife Conservation
and Protection Act and the new legislation of the National Land Act (Kor Tor Chor) and Community Forest Act.
Other initiatives such as the National Strategy (2018-2037)34 are notable, for example, in committing to having
traceability in supply chains “to reduce forest encroachment and deforestation”.
29
30
https://forestinfo.forest.go.th/Content.aspx?id=10408
31
https://dl.parliament.go.th/handle/20.500.13072/597498
32
Land and Community in Protected Area Division, Office Protected Area Restoration and Development, Department of National Parks, Wildlife and
Plant Conservation
33
National Forest Policy 2019, https://4occ.isoc.go.th/km/?p=3608
34
https://leap.unep.org/countries/th/national-legislation/national-strategy-2018-2037
28
Following the 2014 coup, the National Council for Peace and Order (NCPO), renewed efforts to protect the nation’s
forests this included in 2015 “Master Plan of Solving the Problem of Deforestation, State Land Encroachment and
Sustainable Management of Natural Resources”35 and in 2016 introducing “Phlik-Fuen-Phuen-Pah-Su Karn-
Phatthana-Thee-Yang-Yuen” policy36 (Forest Restoration Towards Sustainable Development) to address
deforestation and forest encroachment. The policy included the creation of the Integrated State Land Boundary
Map Improvement Project, the so-called “One Map” (1:4,000 map scale), which aimed to provide a single, clear,
and accurate map of state-owned land.37
The importance of the One Map initiative was highlighted in a 2015 assessment by the Office of Natural Resources
and Environmental Policy and Planning, which is housed within MNRE, which found that 19 Departments across
eight Ministries (including the Office of the Prime Minister), as well as three State Enterprises administer land and
waterways in Thailand, this is under the umbrella of 16 laws (See Annex 3). The result is numerous contradictions
in orders, implementation and enforcement, conflicting data, and programs38. One result was that there was 86.72
million hectares of overlapping land between different government agencies. A key milestone was in February
2022 when the Cabinet approved a map covering 11 Provinces, with the map being the working document for all
government agencies in those provinces within a year39. As of 28th February 2023, the One Map covers 33
provinces (of total of 77 Provinces). The One Map is important in the context of the EUDR for various reasons,
including clarifying the relevant applicable laws, and helping to determine the roles and responsibilities of the
government agencies.
The RTG have taken other measures, including public awareness campaigns of the importance of forest
conservation. The public awareness campaigns are linked to initiatives promoting participation including the
“Pracharat” (Public-Private-People Partnership) framework with the aim to protect forest areas through law
enforcement. This included a plan of action and measures to prevent forest encroachment and reclaim encroached
forest lands. Additionally, the Pracharat signalled efforts to manage degraded watershed forests in mountainous
areas, and to set the goal of forest conservation covering 16.38 million hectares. The Pracharat also included
plans to promote participation of local communities in forest conservation, which included formalisation and
development of the community forestry program, with the main pillar being the long gestating Community Forestry
Act (2019). Furthermore, the RTG made efforts to formalise the support of local communities including enlisting
them as volunteers to protect forests - the number of volunteers under the “Natural Resources and Environmental
Protection Volunteer Network” the “National Parks Volunteer Network” and the "Forest Protection Network"
currently stand as 278,70240 78,92641 and 19,19342 respectively.
The Community Forestry (CF) Act was a significant milestone in formalising the tenure rights of communities that
had been living in and around and using forests. The CF Act builds on the Thai Constitution (2017) which
acknowledged the rights of local communities to “manage, maintain and utilise natural resources […] in a balanced
and sustainable manner.” (Article 43). The Constitution goes on to state that local communities can participate in
the management of natural resources and can “benefit from such undertakings” (Article 57). Since the Act came
into force 13,028 villages covering 1,007,314 ha have received formal tenure43. The country has a target area of
CF of 1.6 million hectares by 202544. Analysis of the CF Act, however, raises concerns including about unclear or
limited opportunities for rights holders to commercially benefit from their CF, for example, through the sale of
timber45. Despite progress in recent years on formalisation of tenure arrangements for many local communities,
concerns are still raised on their rights, especially for those living in NRFs.
35
https://multi.dopa.go.th/criminal/assets/modules/news/uploads/3355465e2bdeb8c8e23ae0fba2b742f0592550f7d7948122258396482430569.pdf
36
https://www.forest.go.th
37
https://www.pacc.go.th/pacc_2015/onemap/index.html
38
https://www.pacc.go.th/pacc_2015/onemap/pages-left-sidebar.html
39
https://www.thaigov.go.th/news/contents/details/51368?fbclid=IwAR0TNjG1mCGb_i4Sji1CFCiGvHrASwORf0xUTwsjuFn7OMiNJQvGTiPyQEw
40
https://datacenter.deqp.go.th/service-portal/tsm-network-system/report/member-overview/
41
https://app.powerbi.com/view?r=eyJrIjoiY2Q5YzQ5MzktNDQ1Ni00YmMxLThiYTgtNDE0OWJhNGVhNTgyIiwidCI6ImVjOGI5MWM3LTMxMDctNGU
5Zi1iMzRmLTY3MmRkZmE5Y2NlMSIsImMiOjEwfQ%3D%3D
42
https://www.forest.go.th/forest-protection/
43
http://env_data.onep.go.th/reports/subject/view/130
44
https://www.recoftc.org/sites/default/files/publications/resources/recoftc-0000379-0002-en.pdf
45
https://www.clientearth.org/media/0unlsvte/briefing-community-forestry-thai-legal-assessment.pdf
29
3.1.2.2 Production of EUDR commodities in Thailand

Large areas of Thailand are used for cultivating agricultural commodities (Table 7). The cultivated area has
fluctuated over time for assorted reasons, including market demands and government programs (e.g., Oil Palm
and Palm Oil Industries Development Strategy 2015-2026).
Table 7 Area under cultivation by smallholders for selected EUDR related commodities46
Year Rubber (1000ha) Oil Palm (1000ha) Coffee (1000ha) Cocoa (1000ha)
2012 3,597.09 701.73 52.67 39.60
2013 3,711.07 718.26 50.95 31.29
2014 3,773.31 750.94 45.09 37.92
2015 3,702.46 813.47 43.53 26.70
2016 3,669.30 865.49 46.08 21.96
2017 3,656.35 926.62 46.61 24.34
2018 4,055.84 959.26 47.74 24.21
2019 4,006.56 978.50 44.31 16.67
2020 3,960.52 995.49 41.27 13.76
Figures 6 a-d show the distribution of the cultivated areas for rubber, palm oil, soya, and coffee in Thailand in 2019
and 2020. They show that most farmers cultivating coffee (49%), palm oil (84%), and rubber (59%) are located in
the southern provinces. One needs to consider the data shared in the tables inset within the figures in the context
of where the forests in Thailand are facing most pressure – i.e. in the Northern (47.9% of forest loss in Thailand in
during period 2021-2022 occurred in this region), and Northeastern (20.7%) regions. The Southern region in 2021-
2022 was the least affected by deforestation with 5.0% (see Annex 3 for more information), though in 2018-2020
forest loss was a bigger issue – with the Southern region accounting for 11.7% of the total forest loss in that period.
46
https://www.oae.go.th
30
Figure 6 a – d Distribution of the cultivated areas of rubber (a, top left), palm oil (b, top right), coffee (c, bottom left) and soya (d, bottom right)
a) b)
c) d)
31
Smallholders and SMEs play important roles in the agricultural supply chains in Thailand. Table 8 provides an
overview of number of smallholders for each commodity and area they have planted. Note that some smallholders
may be producing more than one commodity.
Table 8 Area under smallholder management and number of smallholders for EUDR relevant commodities47
Area under management of

Commodity (year) Number of smallholders (households)
smallholders (ha)
No data for area.
Cattle (2022) Estimated that there are 9,394,111 cattle 1,413,395
owned by smallholders in the country
Cocoa (2020) 228.96 1300
Coffee (2021) 42,913.76 30,833
Palm Oil (2020) 995,487.84 364,864
Rubber (2020) 3,960,520.48 1,700,602
Soya (2020) 13,761.76 15,588
Wood (2022) 206,843.68 58,225
SMEs also play a significant role in the supply chains for the EUDR commodities. Based on the data from Office
of Promotion of Small and Medium Enterprises, in 2021 there were 3,191,706 SMEs classified into four main
sectors (Commercial, Manufacturing, Agribusiness and Service Sectors) and 86 subgroups. Table 9 shows the
SMEs grouped into the commodity categories. Unfortunately, detailed data is not available due to the need for
integration of data between the Office of Small and Medium Enterprise Promotion, Department of Industrial Works,
Department of Internal Trade and Customs Department. Additionally, some SMEs that are involved in the supply
chains are not included in this data, including coffee shops which would be classified under commercial sector,
not agribusiness.
Table 9 Number of agribusiness SMEs that are part of the supply chains for the seven commodities in Thailand in 202148
Commodities Number of SMEs
Cattle 35,723
Cocoa 336
Coffee 2,288
Palm oil 2,214
Rubber 15,593
Soya 146
Wood 80,570
Total 136,870
3.1.2.3 Thailand’s trade with the EU
In 2021, Thailand’s total exports were valued at just under US$244 billion, of which agricultural products accounted
for US$42.795 billion (17.6%) - this breaks down into food products with an export value of US$34.96 billion and
products for agroindustry with a value of US$7.835 billion. The export value of agricultural products in 2021 were
16.11% higher than in 202049 (Table 10).
47
Cattle data from Thailand Livestock Data in 2022, Cocoa from DOAE, data for the other 5 commodities comes from OAE
48
https://data.go.th/dataset/https-sme-go-th-th-page-php-modulekey-348
49
Thailand Foreign Agricultural Trade Statistics 2021, Office of Agricultural Economics
32
Table 10 Value of Thailand’s exports of major agricultural products during 2017-202150
Value (million $US)
2018 2019 2020 2021
Fruits and products 4,067 4,781 5,210 7,207
Natural rubber 6,432 5,447 5,200 7,055

Rice and products 5,750 4,316 3,941 3,734
Cassava and products 2,818 2,281 2,353 3,480
Chicken meat and products 2,869 3,001 2,968 2,929
Fishes and products 3,223 3,053 3,190 2,820
Sugar and products 3,051 3,077 2,019 1,827
Shrimps and products 1,682 1,492 1,287 1,431
Vegetables and products 830 766 767 820
Residues and waste from the food industries; prepared animal fodder 561 518 566 716
Others 8,900 8,923 9,357 10,775
Total 40,182 37,655 36,858 42,795
In 2021 the main export markets for agricultural products were:
• East Asia - US$19.61 billion, which increased from US$15.540 billion in 2020 (26.19% increase)
• Other Association of Southeast Asian Nations (ASEAN) Member States (AMS) - US$8.931, which
increased from US$8.615 billion in 2020 (3.66% increase) (see annex 6 for details on trade in EUDR
commodities with other AMS)
• the Americas (North and Latin America) - US$5.245 billion, which increased from US$4.953 billion in 2020
(5.89% increase)
• EU - US$2.456 billion, which increased from US$1.961 billion in 2020 (25.24% increase) (Table 11).
Table 11 Overall Trade between Thailand and EU51
Value (million US$)

Year
Trade value Export Import Trade balance
2018 40,304 21,000 19,304 1,697
2019 38,228 19,736 18,492 1,244
2020 33,153 17,654 15,499 2,156
2021 39,894 21,674 18,220 3,454
2022 41,038 22,794 18,244 4,551
50
Thailand Foreign Agricultural Trade Statistics 2021, Office of Agricultural Economics
51
Department of Trade Negotiations, (follow up question)
33
The EU is Thailand’s fourth largest trading partner52. In 2021, total bilateral trade between the EU and Thailand
was over US$41 billion. Thailand‘s exports to the EU in that year were just over US$22 billion53. Table 12 shares
the value of Thailand’s exports of EUDR relevant commodities, including to the EU, in 2022. Rubber is clearly the
most significant commodity in terms of trade. Table 12 also shows the importance of the EU market for Thailand
as a share of total exports, this is relevant for the EUDR, but also the renewed efforts to conclude a Free Trade
Agreement (FTA). Annex 7 provides more details on the value of the trade with the EU for all HS codes for each
commodity. Thailand’s exports of EUDR commodities to the EU is, in value terms, roughly half that of the country’s
exports to the other ASEAN Member State (AMS) (see annex 6 for more details on Thailand’s imports and exports
from and to other AMS).
Table 12 Value of Thailand’s exports of EUDR commodities to the EU in 202254
Exports to the EU as share (%) of

Value of exports from Value of total exports
Commodity Thailand’s total exports of EUDR
Thailand to EU (US$) from Thailand (US$)
commodities
Cattle 4,290,000 646,480,000 0.66
Cocoa 2,890,000 68,780,000 4.20
Coffee 320,000 3,580,000 9.01
Oil palm 19,140,000 1,471,510,000 1.30
Rubber 1,732,830,000 15,137,740,000 11.45
Soy 20,000 302,390,000 <0.01
Wood 70,230,000 5,169,930,000 1.36
3.2. Challenges and opportunities for EUDR implementation in Thailand
The interviews, workshops and the literature highlighted a few challenges and opportunities that may support or
restrict the EUDR. These interlinked issues cover:
• Deforestation and degradation

• Awareness of the EUDR
• Due diligence systems
• Capacities
• Governance, legal frameworks, and other initiatives
• Definitions
3.2.1. Deforestation and degradation
The interviewees highlighted the efforts of the Thai authorities, with support from other stakeholders in addressing
deforestation and degradation in the country. A few highlighted, however, that while the rate of forest loss had
fallen in the country some areas were still experiencing numerous pressures on forests (see also Figure 4a and
5b), with Nan being given as an example by RECOFTC, while one of the interviewees from RFD highlighted
problems in Chiang Mai and Mae Hong Son Provinces. Some of the respondents felt that while the rate is
significantly smaller now than in the past, there was still conversion to EUDR commodities. Some of those
interviewed felt that conversion to non-EUDR commodities including maize, sugar cane and cassava, was more
of a concern (see Annex 8 for information on production of the three commodities in Thailand). Table 13 provides
an overview of the perceptions of those interviewed of the deforestation and degradation situation. As many of
those interviewed had a limited understanding of the EUDR, including the commitment to the no deforestation
after the 31st December 2020, some of the responses focused only on illegal deforestation.
52
https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region/countries-and-regions/thailand_en
53
https://tradereport.moc.go.th/TradeThai.aspx
54
Department of Trade Negotiations
34
Regarding the issue of forest degradation – some of those interviewed felt that forest fires were an indicator of
degradation, with some commenting on the air pollution linked to fires during the 2023 burning season as being
particularly bad.
A few felt that as deforestation and degradation had improved significantly the EUDR was therefore not necessary
for Thailand, and in fact it may be counterproductive (see section 4.3). On the other hand, a few also acknowledged
the need to continue to work on the issue, including addressing tenure rights particularly in NRFs.
Some of those interviewed raised the concern that Thailand imports a large amount of EUDR commodities linked
to deforestation and degradation overseas. In 2022 Thailand’s imports of the EUDR commodities was over
US$11.4 billion (see annexes 6 and 7 for more details on Thailand’s trade of EUDR commodities), with soya being
the largest imported commodity in monetary terms (just over US$3.6 billion), followed by wood (just under US$4.7
billion) and rubber (just over US$1.4 billion). TEFSO and FAO FLEGT highlighted the gaps in import controls for
illegal timber, while a representative from FTI also flagged the imports of soyabean meal from Brazil and its use
as a feedstock. Data from ASEAN Stats Data Portal55 shows that in 2022 Thailand imported over US$3.2 billion
of soya products (HS1201 and HS2304) from Brazil.
Thailand also sources non-EUDR commodities from neighbouring countries that are associated with deforestation.
The ASEAN Stats Data Portal also shows that in 2022 Thailand imported nearly US$415 million of maize (HS
1005) from Myanmar, cassava (HS071410) worth just over US$283 million from Cambodia, and crustaceans
(HS0306) worth nearly US$26.8 million from Myanmar. Maize is seen as being one of the main drivers of
deforestation in some areas of Myanmar, while aquaculture is a big cause of mangrove loss in the country, and
cassava is seen as being one of the key crops for forest conversion in Cambodia.
In terms of getting detailed data on the causes of deforestation a couple of the interviewees from international
NGOs suggested using Global Forest Watch (GFW) database and a 2020 report from the US Forest Service56 for
data, as well as academic research from Pendrill et al (2020)57.
Table 13 Overview of the challenges and opportunities for EUDR implementation regarding addressing deforestation and degradation raised by
stakeholders in the workshops and interviews (+ denotes opportunity, - denotes challenge)
Stakeholder Organisation Addressing Deforestation and degradation

group
Government DMCR + Data shows decreasing enforcement actions (2018-2022), but this may also be linked to
agency budget cuts in enforcement agencies
- Still some clearing of forest land and conversion, especially for oil palm plantations and
aquaculture.
+ Significant efforts made and improvements during NCPO 2014-2019
DNP +/- Illegal logging and encroachment are still a concern.

- Measuring degradation is an issue. DNP uses tree volume to determine degradation
measured during National Forest Inventory (NFI) that have been held every 3-4 years. Is only
possible to estimate degradation for sample plots for NFI.
+ DNP has effective system (iForMS58) for monitoring deforestation, and also employing
SMART Patrol system in protected areas (working with WCS and WWF).
FTI +/- Thailand imports great deal of soya products from Brazil, some of which may be linked to
deforestation in the country.
55
https://data.aseanstats.org/trade-annually
56
Tenneson, K., Patterson, M.S., Jadin, J., Rosenstock, T., Mulia, R., Kim, J., Quyen, N., Poortinga, A., Nguyen, M.P., Bogle, S., Dilger, J., Marlay,
S., Nguyen, Q.T., Chishtie, F., and D. Saah. 2021. Commodity-Driven Forest Loss: A Study of Southeast Asia. Washington DC. 196pp.
https://servir.adpc.net/publications/commodity-driven-forest-loss-astudy-of-southeast-asia
57
Pendrill, F., Persson, U. M., Godar, J., Kastner, T., Moran, D., Schmidt, S., & Wood, R. (2019). Agricultural and forestry trade drives large share
of tropical deforestation emissions. Global Environmental Change, 56, 1-10.
58
DNP’s Intelligence Forest Monitoring System (iForMS) that is developed by the Geoinformatics Division, Information and Communication
Technology Center, DNP (https://iforms.dnp.go.th) - iForMS uses Landsat 8 and 9 image data to monitor the forest resources with near real-time
processing. The two forms of Landsat data are used to identify areas of deforestation (larger than 1 rai), with those areas identified being shared
with the DNP field unit for investigation.
35
RAOT +/- Work still needed, EUDR can help.

+/- 800,000 ha of rubber plantations in NRF – it must be addressed.
RFD +/- Work still needed, especially in NRF. Shifting cultivation especially in Chiang Mai and Mae
Hong Son Provinces and forest fires are still a problem.
+ Benefits of community forest program.
+Recognises value of EUDR. When the price for maize and rubber are high then more pressure
on forests
Smallholder Rubber & oil palm - Deforestation and degradation are still problems, though on a smaller scale. Main issues
farmer – Krabi linked to unclear tenure rights.
National NGO PFPC +/- Work still needed
RNRF + No concern with cut-off date as it aligns with Thai laws
RECOFTC Thailand +/- Great progress in recent years, but more to be done.
TEI + Clear systems in place to address deforestation, including clear forest boundaries.
- Degradation is still a concern – example of continuing forest fires.
TTA - Deforestation and degradation are still a concern, some of which is caused by smallholders
focused on domestic market
WWF, Thailand +Great improvement in recent years. Only a few areas where encroachment and conversion
continues, including for non-EUDR commodities (maize, sugar cane and cassava)
+DNP and RFD are doing their work effectively, though they are some challenges in forests
near urban areas (e.g. Thap Lan National Park).
+Access to technology has helped with enforcement.
International EU-ABC +/- Many countries in region, including Thailand, made good progress
NGO
RECOFTC Regional +/- DD situation reflects progress being made on tenure rights of local communities, but work
Office (RO) needs to still be done.
- Thailand also has a deforestation footprint beyond its borders, including in neighbouring
countries
International EFI RO + Thailand made great progress

Organisation
EFI Thailand +/- Expansion of agricultural land is main driver of deforestation, now moving further into
Northern and upper North-eastern region.
+ Little illegal logging (only high value timber)
+ Enforcement is strong.
+VPA helped
FAO FLEGT (ex- + Little forest conversion now compared to past.

consultant) + RTG made great effort, with support from stakeholders
Anonymous - Need to consider that some forest loss is more sensitive than others, for example, consider
that some is linked to encroachment by large companies and prominent individuals. Example
given was Thap Lan National Park where encroachments included by tourist resorts. IPLCs
are too easily blamed.
3.2.2. Awareness of EUDR
The limited awareness of the EUDR came up continuously during the interviews and workshops (Table 14). This
came in two forms: 1) Where those interviewed highlighted that key stakeholders knew little of the fundamentals
of the EUDR, and 2) That many of those interviewed had not read the EUDR, and therefore many of the questions
and concerns they raised were addressed in the EUDR itself.
Table 14 Overview of the challenges and opportunities for EUDR implementation regarding awareness of the Regulation raised by stakeholders in
the workshops and interviews (+ denotes opportunity, - denotes challenge)
Stakeholder Organisation Awareness

group
DFT - Awareness among SMEs is very limited, is urgent priority or else they will be penalised.
36
Government DMCR + / - Recent and basic understanding. Felt that awareness gap exists, and should be addressed
agency
DNP +/- DNP has good experience with international cooperation, including on deforestation and
degradation. Keen to engage on EUDR but have numerous questions and concerns.
- Felt that EU could have been more active in engaging with RTG in preceding months, concern
that Thai standards will be ignored.
DTN + Clearly engaged in awareness raising and EUDR readiness

- Questioned spirit of the EUDR, including undermining SDGs.
FTI - Feels that conflicting messages coming from EU on scope of EUDR, and plans for
implementation
+ Keen to engage with RTG and EU to address challenges.
- Acknowledged awareness gaps on EUDR details
+VPA has helped to create good relationships with EU authorities
FIO - EUDR is new for FIO (FIO main market is domestic)

- EU needs to clarify benefits to producer countries, provide incentives, not just penalties.
+/- Assumes certification very closely aligns with EUDR
- Unclear on rationale for cut-off date
OAE +High level of awareness. OAE have received regular updates from MOAC office in Brussels
- Urgently need to have EUDR focal agency in government – suggestion is that it will be RFD
as they would lead in monitoring deforestation and degradation.
RAOT + MOAC started EUDR awareness raising in 2021.
RFD +/- Mixed thoughts on awareness.
TEFSO - Expectation that wood supply will completely pass EUDR
Private sector Plan Creation - Numerous concerns and questions regarding EUDR and possible impact on their company.
Smallholder Rubber smallholder - Knew little of the EUDR and its requirements
in Songkla - Has FSC certification, and asks if this is sufficient for EUDR?
Rubber & oil palm + Awareness raising ongoing through radio and TV, as well as through networks
farmer in Krabi - Has numerous questions
National NGO FGTBA - Aware of EUDR since August 2022, but feels opportunities missed to prepare since then as
details not shared and government agencies are not being proactive
National NGO PFPC - Expectations that existing DDS for wood are close to sufficient
RNRF - Expectation that certification meets EUDR requirements
RECOFTC, - Urgent priority.

Thailand
TEI - Urgent priority for all stakeholders.
TTA - Awareness raising is much needed, if it is not done quickly, it gives little time for smallholders
and SMEs to respond.
+Large companies are better informed than most government agencies, and SMEs and
smallholders.
- Also concerned about other EU regulations (e.g., CBAM) that may impact Thailand
WWF, Thailand - Concern if RTG has limited awareness or misunderstanding then ultimately smallholders will
pay
International EU-ABC - Awareness raising is an urgent priority – actors need more information.
NGO - EU also needs to understand situation on the ground in Southeast Asia
GPSNR - Many awareness gaps need addressing urgently (incl. assumption that EUDR is only direct
trade from Thailand to EU)
RECOFTC RO - Little apparent outreach conducted by EU.

- Many questions need to be addressed urgently – if not then ultimately the smallholders and
SMEs will pay the costs.
EFI, RO - Awareness raising Is urgently needed, considering the tight timeline.

37
International EFI, Thailand +/- EUDR is not complex, and relevant information is already available, but need to ensure
Organisation stakeholders in Thailand can access and understand – TEFSO can play key role here.
FAO FLEGT (ex- - Little apparent outreach conducted

consultant)
The RTG is clearly taking steps to prepare for the EUDR, including improving understanding of the EUDR. The
Prime Minister, for example, responded to the proposed EUDR encouraging appropriate organisations in the
country to make necessary preparations59. Other responses include from the Minister of Agriculture and
Cooperatives (MOAC) and the Department of Trade Negotiations (DTN). The DTN, for example, also organised
an internal meeting on 1st February 2023, on Thailand’s EUDR readiness, and plans to ramp up efforts on
preparations. Kasetsart University (KU), the country’s leading university on agriculture and forestry, hosted
workshops in February and March to address some of the questions that Thai stakeholders have on the EUDR,
CSOs in the country are also preparing themselves, for example, RECOFTC, a regional NGO working on
community forestry, including in Thailand, organised an internal workshop to identify the challenges and
opportunities that may arise from the EUDR, and create a workplan to ensure that, for example, smallholders and
SMEs are not penalised, but also that civil society is in place to support the process.
Many of the stakeholders interviewed and those participating in the KU workshops demonstrated a good
understanding of the EUDR, however, one of the concerns often raised is that some of the stakeholder groups are
yet to engage themselves or be engaged on the issues around the EUDR. This is reflected in the considerable
number of questions raised in the interviews but also in the workshops – these questions were often posed in the
context of the perceived tight timeframe for the EUDR implementation.
Participants in the RECOFTC workshop flagged that there is limited awareness of the EUDR among RECOFTC
country offices and with its key partners. The feeling was awareness was highest in Thailand and Viet Nam. In
fact in Thailand, it was clear that RECOFTC had a good level of awareness, but the concern was that civil society
partners had limited understanding, including believing that the EUDR was only relevant to CSOs working in the
forestry sector - i.e. not those working in agriculture. One of the conclusions from the workshop was that if the lack
of awareness were not urgently addressed then those that are often challenged when it comes to access to
information – particularly smallholders, would suffer the most once the EUDR came into force.
The questions raised by interviewees and workshops participants is worth sharing to better understand their
responses regarding the potential impacts of the EUDR, particularly as there is a degree of misunderstanding of
the objectives and scope of the EUDR. Many of the questions are addressed in the EUDR itself, and in the
European Commission document “FAQ – EU deforestation Regulation” that was published in June 2023:
• What is the purpose of the pre-amble in the first half of the draft EUDR60 (pages 3-57 of the EUDR version
dated 19th April 2023)?
• Section 50 of the pre-amble (of the draft and final EUDR) states: “When sourcing products, reasonable
efforts should be undertaken to ensure that a fair price is paid to producers, in particular smallholders, so
as to enable a living income and effectively address poverty as a root cause of deforestation.” One of the
interviewees requested additional information from the EU on this. It was warmly welcomed but it may also
have implications, including being a deterrent for some companies to source from smallholders if the “fair
price” is higher than the market rate. The same respondent also asked why this ambition is not explicitly
covered in the text of the EUDR itself.
• What was the reasoning for including these seven commodities? Will additional commodities be added
before EUDR comes into force? How much warning will be given if this happens?
59
https://www.thaigov.go.th/news/contents/details/65546
https://dld.go.th/th/index.php/th/newsflash/director-news/25679-eu-abc
60
Note the references to the EUDR text is for the final version dated 31st May 2023 unless stated otherwise.
38
• There were clear awareness gaps on the due diligence requirements and components. This is an issue
especially as there are many gaps in Thailand on chain of custody for most of the EUDR commodities,
and there needs to be time for awareness raising and capacity development for smallholders and SMEs
to ensure they can meet the requirements in a cost-efficient manner.
• How will the EUDR align with regulations of the EU Members states (e.g., France and Germany) and other
EU initiatives (e.g. Corporate Sustainability Due Diligence Directive (EU-CSDDD))? Would efforts be made
to also align requirements for initiative from non-EU countries, such as the UK’s Environment Act?
• There was also concern on the differences in definitions in Thailand – e.g., for forests, and the implications
this will have for the EUDR.
• There was also confusion if the different definitions of SMEs between the EU and Thailand may have
implications, regardless of who was the Operator and Trader. Specifically, clarification was sought on if
supply chain includes SMEs, but are not the actual operator or trader in the context of the EUDR, would
they fall under the 24-months window from entry into force of the EUDR. This question was based on the
concern that SMEs in Thailand will face numerous challenges to meet the 18-months deadline. Linked to
this question was if the risk assessment and risk mitigation may help to address the challenges that
smallholders and SMEs in Thailand with addressing the due diligence requirements, including the geo
location data, but also segregation of the commodity.
• It would be very useful to clear communication on if and how the different voluntary standards / certification
schemes for the different commodities can align with the EUDR. Many Thai stakeholders hoped and even
expected that certification would meet EUDR requirements. On the other hand, some of the interviewees,
especially from international organisations, reflected that while certification schemes universally fall short,
there are many components that may be of use.
• In reference to Article 2(27) and its definition of plot of land as “land within a single real-estate property, as
recognised by the law of the country of production, which enjoys sufficiently homogeneous conditions to
allow an evaluation of the aggregate level of risk of deforestation and forest degradation associated with
relevant commodities produced on that land” – the concern was how communal ownership, which is
relevant for some forms of community forestry would be considered.
• Clarify in reference to Article 2(28) product total land holding of the smallholder is more than 4 hectares,
but their EUDR commodity plantation, e.g., rubber, is less than 4 hectares do they need to provide
geolocation for their harvested rubber.
• A source of confusion for one interviewee was the possible conflict between Article 2 (28) and Article 9(d)
on if geolocation was needed for cattle?
o Article 2 (28): “for plots of land of more than four hectares used for the production of the relevant
commodities other than cattle, this shall be provided using polygons with sufficient latitude and
longitude points to describe the perimeter of each plot of land.”
o Article 9 (1d): “for relevant products that contain or have been made using cattle, and for such
relevant products that have been fed with relevant products, the geolocation shall refer to all the
establishments where the cattle were kept; for all other relevant products of Annex I, the
geolocation shall refer to the plots of land”
• Clarify if the product is comprised of EUDR commodities that are all sourced from plots that are less than
4 hectares in size if georeferencing for all sources of the commodity is needed?
• In the case of cattle, do the traders need to provide information and conduct due diligence on all the feed
provided to the cattle?
• A few of the interviewees are also directly and indirectly seeking clarity on Article 30 (Cooperation with
third countries):
39
o Considering the perceived tight timetable there is a need to clarify the support for state and non-
state actors under the partnership development.
o What will be the requirements of the RTG regarding mandating of “full participation of all
stakeholders, including civil society, indigenous peoples, local communities, women, the private
sector including microenterprises and other SMEs, and smallholders”. One of the lessons learned
from the VPA process is the value of multistakeholder processes, but there is also a need to ensure
non-state actors have the capacity and feel safe to contribute to these processes.
• In reference to Article 30(5).
o How is the EU planning to engage with China? – is the EU conducting a similar assessment and
does this assessment have appropriate emphasis of the large number of commodities that
Thailand exports to China.
o Thailand also sources products from neighbouring countries – it would be useful to see the impact
assessments for those countries to help coordination. This was raised in one of the interviews with
RFD, as government agencies in Thailand and private sector will have to engage with their
suppliers in Lao PDR and buyers in China were the examples provided. The interviewee flagged
that it is anticipated that the Thailand International Cooperation Agency (TICA) may be engaged
in this support.
• Some of the respondents also highlighted the need for the EU to clarify the reference for verifying that the
product has not come from forest cleared after the 31st December 2020 cut-off date. Will it be that the
reference is a detailed map produced by the EU showing forests in Thailand on that specific date?
• There was also clarification sought on if land that was previously categorised and used as agricultural land
was, for example, abandoned leading to natural forest regeneration could the trees be cleared after the
31st December 2020 cut-off date and used again for agriculture if it is in accordance with the national law?
• Clarify plans for the VPA - specifically if the TLAS developed as part of the VPA would meet all the EUDR
requirements? As it seems it will not, it would be beneficial for the EU to clarify if addressing these gaps
can be included in the VPA – assumption being that the VPA will continue to move forward.
• Clarify that the EUDR goes beyond direct trade to the EU. For example, a couple of respondents were not
clear if the EUDR commodity product is exported to China and then onto the EU if it falls under same
requirements.
• There were a couple of related questions that also came up from two sources – how will tires (and leather
car upholstery) on cars be addressed, as it does not appear they are included in Annex 1? A similar type
of question was also raised about how the EUDR (and EUTR) will deal with wood pallets that are imported
as part of packaging for another product? Both the car and pallet questions were flagged as a potential
loophole, and relevant for Thailand.
• Why not start all countries on low risk, and then review after 18 months? This will give countries and
companies more time to set up the systems. By starting all countries on standard then the concern is that
this will disrupt a large amount of the supply chains as there is insufficient time to meet the stringent
requirements compared to if all countries were low risk.
It should be noted that since conducting the interviews for the assessment during February and March 2023 further
EUDR awareness activities have been held including those focused on the private sector, such as by Preferred
by Nature and Double Helix. Furthermore, review documents have also been shared such as those by ITTO.
3.2.3. Due diligence, including chain of custody (CoC)
In general terms there was mixed confidence on Thailand’s ability to meet the EUDR’s due diligence requirements
(Table 15), these were partly framed by the different levels of understanding of the Regulation. Nevertheless, there
40
was a high level of concern for the existing systems in place in Thailand to ensure that the requirements can be
met in a timely and cost-effective manner. For example, the respondent from RAOT flagged that the system for
verifying the rubber chain of custody from mill to market was more or less in place, but it was not the case from
the smallholder’s plot of land to the mill. After the interviews were completed RAOT stated in a meeting with a
delegation from the EU that it has made great progress in plotting the location of rubber plantations and is also
investing in supporting other areas to ensure EUDR compliance61.
The world’s largest tyre manufacturers Michelin and Bridgestone may face challenges. Michelin, which is
estimated to source natural rubber from approximately 480,000 ha62 of plantations a year, will be based on publicly
available documents face challenges to meet the EUDR requirements. The company, which is headquartered in
France, owns a very small area of natural rubber plantations in Bahia, Brazil. It relies on buying natural rubber
from joint ventures, including the Thai based Nteq Polymer Company limited, and non-affiliated suppliers, including
in Thailand. The company has strict requirements on suppliers to ensure legality and sustainability and has
systems in place for monitoring adherence. However, some of Michelin’s suppliers will be challenged to meet the
EUDR requirements. For example, Michelin’s “Sustainable Natural Rubber Roadmap 2020-2025”63 highlights the
work still to be done especially in supply chains with smallholders - the company has a target of “100% of supply
from smallholders traceable to jurisdictional level by 2030”. This traceability to jurisdictional level, which in Thailand
would be to the provincial level, which would not comply with EUDR requirements.
Bridgestone, which is second to Michelin in the global production of tyres, sources approximately 20% of its natural
rubber from Thailand64. The company, which is committed to achieving sustainability in its sourcing of natural
rubber by 2050, highlights the challenges to achieving this including “that the great majority of natural rubber is
sourced from small and typically unsophisticated landholders from rubber-producing regions worldwide.” The
concern being that the complexity of the rubber supply chain, including the large number of smallholders and
SMEs involved. The concern is that there is limited time to get the message across, as highlighted by the
respondent from GPSNR, and ensure the system is in place to support information collection and verification.
Annex 7 provides an overview of the supply chains for the seven commodities, and an overview of the supply
chain controls for some of the commodities. This includes TLAS which has been given impetus through Thailand
entering into VPA negotiations with the EU. Though work is still to be done – addressing the import controls, but
also the geolocation requirements.
Table 15 . Overview of the challenges and opportunities for EUDR implementation regarding due diligence systems raised by stakeholders in the
workshops and interviews (+ denotes opportunity, - denotes challenge)
Stakeholder Organisation DDS, incl. CoC

group
Government DMCR + Not a problem for large companies.
agency - Smallholders will face challenges to comply
DNP - Still a relatively large amount of illegally imported timber entering Thailand and then being
processed as domestic timber. Often is traded to China via Lao PDR.
DFT + CoC for wood is well developed, however, other commodities will need work to prepare.
FTI + Not a problem for rubber and wood

- May be big challenge for cattle, considering use of soy in feed and the volume of imports,
including from Brazil, especially as no import control in place. Concern is that Brazil will not
have a system in place to support Thai DDS, including compliance with cut-off date.
FIO + Working on CoC for wood.
61
https://siamrath.co.th/n/455251
62
https://app.impaakt.com/analyses/michelin-sourced-32mn-t-of-raw-materials-using-over-400k-ha-of-land-amid-deforestation-concerns-57978
63
https://purchasing.michelin.com/wp-content/uploads/sites/50/2022/07/Sustainable-Natural-Rubber-Roadmap-2020-2025_V1.1_EN.pdf
64
https://www.bridgestone.com/responsibilities/social/procurement/
41
+ Aim for 100% FSC certification for all wood plantations by 2025.
OAE +/- Some companies in cattle, cocoa, coffee, and soya supply chains collect traceability data,
though is more for business management than sustainability and legality, rubber and palm oil
do not have from field to mill.
RAOT - Incomplete for rubber (smallholder to mill is missing) – note that subsequently statements from
RAOT highlight that progress is being made on this65
- Factories often have different DDS.
-Limited access to information from intermediaries
-Small area that is certified (4160ha)
+ Target of 2.88 million hectares certified by 2037
RFD + Wood well placed thanks to VPA

- Concern that other commodities might not be as well placed
+RTG making efforts including through “Single Window” program, moving to efficient digital
procedures that can complement due diligence.
TEFSO +/- Expectation that wood supply will completely meet EUDR requirements
+ RFD have good data on forest area etc. To show where forests are lost, and main cause.
Private sector Plan Creation - Company has CoC to the mill, but recognise it will not be sufficient for EUDR
Smallholder Rubber smallholder - Concerned about having all documents ready to share e.g., ownership of plantation.
- Songkla - Concerned of costs for FSC (FSC not delivering price premium as promised by RAOT), and
that will be similar costs for meeting EUDR.
National NGO FGTBA - Numerous challenges relating to creation of much needed systematic DDS covering all
commodities and the whole country.
National NGO PFPC +/- Expectations that existing systems for wood are close to sufficient
PNPOPA + Certification (RSPO) can be big support for EUDR

+ DDS is easy for PO as is nearly all on former agricultural land
- /+ Few smallholders have need for DDS but is integral to RSPO. As RSPO grows it will help.
RNRF - Concern for extra costs for DDS, as current DDS are incomplete.
- Smallholders do not benefit from certification
RECOFTC + Green Book (also known as e-Farm) may help

Thailand - Certification schemes are not enough
- Concerns about costs. Problem highlighted by challenges for smallholders getting certified
TEI - Different challenges for different commodities. Wood is likely more developed. Challenge is
that few smallholders have certification which would help.
TTA - Members main market is China, less requirements for certification (and DDS)., however, in
future will prioritise other ASEAN Member States, as well as Japan and USA which may have
more requirements.
WWF, Th +/- Where RTG and NGOs have focused on the past there are good foundations for DDS.
International EU-ABC - Will be too burdensome for some companies, which will have implications for smallholders
NGO and SMEs
- Great deal of work needed and may not be realistic in timeframe.
GPSNR - Likely too costly to complete for rubber, especially in some of the remoter areas of the country.
- Challenge of getting smallholders organised to get certification, likely happen for EUDR DD
- Some intermediaries will be reluctant to share information on their supply chain
GIA - Costly to create CoC for rubber, impractical in short period for EUDR
- Some actors resist transparency of supply chain
- Supply chains are often complex
RECOFTC - Challenges facing smallholders for getting certification, will likely continue for EUDR.
Regional Office - Transparency from DDS will be beneficial but there are also risks
65
https://siamrath.co.th/n/455251
42
- Confusion among partners on what is the aim of a DDS, and its components
- Practicality of segregation is highly questioned, especially in the short term.
- Numerous capacity gaps among stakeholders on effectively engaging in sustainable and legal
forest management (eucalyptus, rubber wood and latex, teak)
International EFI (Kuala Lumpur) + TLAS is good, but some work still needed.
Organisation - Some actors may resist transparency of supply chain
- Significant work to build traceability framework
- Certification does not go far enough, but can support
EFI, Thailand +VPA has laid good foundations for wood supply chain, however, some of supply chains –
particularly palm oil and rubber have very weak DDS.
- Main challenges will be in the palm oil and rubber sectors.
FAO FLEGT (ex- - Some trade actors may resist transparency of supply chain.
consultant) - Need to better understand DDS and the likely costs for smallholders and SMEs
+ Great progress on certification across the commodities, good foundation, but there are clear
gaps.
The starting point for many of the respondents from international organisations and NGOs and all the smallholders
and their civil society representatives was that smallholders struggle to get certification, which is borne out by the
data shared by different government organisations, including research by TEFSO66. These struggles, it was felt,
will continue for meeting the EUDR’s due diligence requirements.
For example, according to RAOT67, as of November 2022, there were only 4,160 ha of FSC certified rubber
plantations in Thailand, of which farmer cooperatives make up a majority:
• 8 farmer cooperatives were FSC certified with an area of 2,876.07 ha (6,060.01 tons production).
• 6 farmer cooperatives that have successfully completed the FSC assessment and now wait for the
official announcement. The cooperatives cover an area of 2,153.98 ha (3,365.60 tons).
• 9 farmer cooperatives are in the process of responding to feedback from FSC (2,230.87 ha and
3,485.74 tons).
• 38 farmer cooperatives are in the process of seeking FSC certification (16,016.51 ha and 25,025.79
tons).
These challenges facing certification uptake affects other commodities - for example, only 2.8% of Thailand’s palm
oil supply is RSPO certified, including 34 groups representing 1386 smallholders (with holdings of 4442.7ha)68.
One of the smallholders interviewed highlighted the problem - the value of certification is questionable – with its
high costs and limited benefits (e.g., no price premium). There are various standards and certification schemes
used in Thailand that are recognised by the RTG (Annex 9).
Research of smallholders in Thailand found that numerous variables were important regarding smallholders
pursuing certification – those with larger holdings, diverse income sources and better access to services were
more likely to pursue RSPO.69 Other concerns include the lack of support by the RTG and the structure of the
industry in the country, including in the role of intermediaries70 (often referred to as “middlemen” in the interviews,
and also sometimes known as “ramps”) in the supply chain and their apparent resistance towards certification. For
palm oil, for example, the intermediaries often collect the oil palm fresh fruit bunch from several smallholders and
transport to mills. FAO FLEGT, EFI, Green Invest Asia and GPSNR were concerned that some of these
stakeholders would not be keen on having transparency in their supply chain with the main concern that this could
66
https://tefso.org/en/sustainable-supply-chain-management-in-thai-leather-and-food-industry/
67
https://km.raot.co.th/uploads/dip/userfiles/intra_%E0%B8%9D%E0%B9%88%E0%B8%B2%E0%B8%A2%E0%B8%A2%E0%B8%B8%E0%B8%97
%E0%B8%98%E0%B8%A8%E0%B8%B2%E0%B8%AA%E0%B8%95%E0%B8%A3%E0%B9%8C%E0%B8%AD%E0%B8%87%E0%B8%84%E0
%B9%8C%E0%B8%81%E0%B8%A3/Strategic-Plan%20phase%2020Y%20(Final).pdf
68
https://www.ofimagazine.com/news/rspo-launches-thailand-sustainable-palm-oil-alliance-with-local-partners
69
Nupueng, S., Oosterveer, P., & Mol, A. P. (2022). Global and local sustainable certification systems: Factors influencing RSPO and Thai-GAP
adoption by oil palm smallholder farmers in Thailand. Environment, Development and Sustainability, 1-26.
https://link.springer.com/article/10.1007/s00267-020-01323-3
70
Degli Innocenti, E., & Oosterveer, P. (2020). Opportunities and bottlenecks for upstream learning within RSPO certified palm oil value chains: A
comparative analysis between Indonesia and Thailand. Journal of Rural Studies, 78, 426-437.
43
facilitate competitors using information to cut in and take the suppliers. Additionally, RAOT in the 17 February
workshop highlighted the challenges they have in getting information on and from intermediaries in the rubber
supply chain.
Many of those interviewed, especially Thai stakeholders, were hopeful that certification schemes would be
sufficient for meeting the EUDR’s requirements. Part of this appeared based on hope rather than on understanding
of the EUDR. A few of those interviewed gave specific examples where the certification schemes will support, but
not be completely sufficient for the EUDR. The consideration of the chain of custody components of the schemes,
with emphasis on legality (e.g., RSPO Principle 2 - Operate Legally and Respect Rights), may help. Many of those
interviewed, particularly those from international organisations highlighted gaps in these standards meeting
specific areas of the EUDR:
1. Providing “Geolocation of all plots of land where the relevant commodities that the relevant product
contains, or has been made using, were produced” (Article 9 (d))
2. Supporting due diligence to demonstrate the product is deforestation-free after the 31 December 2020 cut-
off date (Article 2).
3. Emphasis on complete segregation of compliant and non-compliant products in the EUDR (Article 9(d))
4. Concern on how the schemes adhere to “relevant legislation of the country of production”, including
consideration of the principle of free, prior, and informed consent.
Regarding the issue of providing geolocation (Article 9 (d)) there is widespread assumption that smallholders can
readily use their mobile phones to collect and share the necessary information regarding the geolocation
coordinates of their plots of land, this was also shared in the EU Commission’s “FAQ – EU deforestation
Regulation”71. The National Broadcasting and Telecommunications Commission (NBTC) in their 2021 Annual
Report stated that just under 97% of the population have mobile broadband service72. Some international
databases provide maps of coverage of mobile networks in the country, sharing that limited coverage is
concentrated in remote areas in the country, especially in national parks73. Nevertheless an assessment of the
opportunities and challenges for using mobile phones for this purpose should be further explored.
The responses to EU’s Fitness Check of the FLEGT and the EUTR Regulations that was conducted in 2020-
202174 highlighted some of the challenges and likely impacts of the EUDR. This included the fact that there was
limited understanding of the concept of due diligence that was fundamental to the EUTR, among some
stakeholders. The Fitness Check also found that there are many challenges for the verification of the information
collected for the due diligence for the EUTR, including ensuring they are trustworthy and free from corruption. One
of the respondents felt that time would be needed to ensure that the due diligence systems are up and running
and available in an appropriate language for the competent authorities (CAs) in the EU (i.e., English).
An additional area of concern raised by GPSNR and RECOFTC was the use of an agreed upon reference for state
of forests in Thailand for the 31 December 2020 cut-off date. RFD have satellite data for the period January to
March 2021. The respondent from GPSNR suggested that the EU provide high resolution maps for each country
with sufficient detail of the forest area on the 31 December 2020 cut-off date. The worry is that some countries
may not have high quality maps for that specific date, and that there may be conflicting maps within the country –
as demonstrated by the need for the One Map initiative in Thailand. The situation regarding the cut-off date is
particularly relevant considering that Thailand does not have national map for monitoring forest degradation in the
country.
The Department of Agriculture Extension has the e-Form system75 for the farmer to register their land holding,
including details on the crops. The system is also known as “Digital Farmer Registration Book” and “Farmbook”
71
https://environment.ec.europa.eu/system/files/2023-06/FAQ%20-%20Deforestation%20Regulation_1.pdf
72
https://www.nbtc.go.th/getattachment//Information/AnnualReport/57955/NBTC-Annual-Report-2021.pdf?lang=th-TH
73
https://www.nperf.com/en/map/TH/-/19345.AIS-Mobile/signal/?ll=13.152388677984096&lg=101.49499999999998&zoom=5
74
https://op.europa.eu/en/publication-detail/-/publication/c16cc71e-5a5a-11eb-b59f-01aa75ed71a1/language-en
75
https://efarmer.doae.go.th/
44
and it can be downloaded free of charge and setup on a mobile telephone or tablet. The Farmbook can support
famers’ access to information. Additionally, the Department of Agriculture Extension can use the information
provided by the farmers to support implementation and enforcement of government programs, and monitor, for
example, the purchase and use of chemicals. Farmers are requested to update their data annually. A few of those
interviewed felt that there was potential for the e-Form system to support data management and access for the
operators and traders. Additionally, the Cattle Industry Traceability System was felt to provide a platform for
traceability for cattle products (see Annex 7). A further positive note is Thailand’s commitment to traceability in its
supply chains to reduce forest encroachment and deforestation in the National Strategy (2018-2037). Additionally,
the ASEAN’s Single Window program may also provide opportunities to harmonise the documents collected and
shared for trade within the bloc, not just for verifying payment of taxes and duties, but also verifying compliance
with national laws.
One of the respondents, in a post interview follow up email, highlighted the abundance of resources that are
available to support companies in their efforts to strengthen their supply chain controls, referring to the tools
developed by the Accountability Framework Initiative (AFi)76, and GPSNR7778. The respondent also highlighted the
different tools that can be used to monitor the risk management in the supply chains including Trase79, and
Zoological Society of London’s (ZSL) Sustainable Palm Oil, Timber and Rubber (SPOTT) platform80. While Trase
does not currently include products originating from Thailand it allows the exploration of, for example, of imports
of soya from Brazil – which has a, so called, deforestation exposure of 10,438 ha81. There are also other numerous
resources that have or are being developed since the interviews were held including by, for example, OECD and
FAO82, as well as Preferred by Nature83.
3.2.4. Capacities
The issue of capacity gaps was raised by many of those interviewed (Table 16), this, like all the challenges and
opportunities needs to be taken in the context of the information gaps that the interviewees had on the EUDR
(Section 4.2.2). The capacity gaps relating to government agencies invariably stemmed from concerns about
budget and staffing, this is set against background of budget cuts in many agencies – for example, DNP and
DMCR were explicitly highlighted in the interviews, but also in the desk survey.
CSOs were viewed by national and international NGOs as likely to play a key role in addressing these capacity
gaps, especially for smallholders and SMEs, however, many raised the concern that national CSOs may have
limited knowledge of the EUDR. For example, RECOFTC pointed out that civil society working outside of forests
and VPA appear to be unaware of the EUDR.
One of the concerns raised in the interviews directly linked to capacities is that operators, and government officials
will be challenged to understand all the requirements linked to the different initiatives to reduce trade in forest risk
commodities that are or may be introduced by the EU (e.g., EUDR, EU-CSDDD), its member states (e.g.,
Germany’s Act on Corporate Due Diligence Obligations in Supply Chains), the USA (Forest Act), and its States
(e.g., California, New York), and other markets such as the UK (Environment Act and possibly the Financial
Services and Markets Bill). For example, the difference in focus of the proposed Forest Act which is focusing on
legality, while the EUDR goes beyond that banning deforestation from supply chains. Furthermore, the most recent
draft of the Forest Act and the EUDR also have slight differences on the HS codes where the commodities
76
https://accountability-framework.org/how-to-prepare-for-new-
eudr/?utm_source=Accountability+Framework+Updates&utm_campaign=f72efb2494-
NEWSLETTER_May2023&utm_medium=email&utm_term=0_ca9f0085c8-f72efb2494-108233277
77
https://sustainablenaturalrubber.org/news-publications/statement-by-the-global-platform-for-sustainable-natural-rubber-on-proposed-new-eu-
deforestation-regulation/
78
https://www.european-rubber-journal.com/article/2092634/gpsnr
79
https://supplychains.trase.earth/?utm_source=trase-homepage
80
https://www.spott.org/about/
81
https://explore.trase.earth/explore/BRAZIL/SOY/commodity_deforestation_total_exposure?includes_domestic=true&year=2020&region_type=MUNI
CIPALITY&region_level=6&country_of_import=THAILAND
82
https://mneguidelines.oecd.org/OECD-FAO-practical-business-tool-on-deforestation.pdf, https://www.oecd-ilibrary.org/finance-and-
investment/oecd-fao-business-handbook-on-deforestation-and-due-diligence-in-agricultural-supply-chains_c0d4bca7-en
83
https://preferredbynature.org/EUDR
45
overlap84. This was raised by a few of the interviewees. The concern here was that there may be confusion among
the supply chain actors, and increased demands on government officials in producer countries to ensure that these
actors are aware of the demands. The RTG and supply chain actors will clearly need and can benefit from being
proactive in engaging with these different initiatives – to understand the different requirements, assessing the
needs, including capacities to meet these, and develop programs to ensure they are being met, including linking
national programs (e.g., National Strategy 2018-2037) and targets (e.g. area of rubber and palm oil being certified)
with these international initiatives. The benefits from being proactive include getting competitive advantage for
Thai producers.
Table 16 Overview of the challenges and opportunities for EUDR implementation regarding capacities raised by stakeholders in the workshops and
interviews (+ denotes opportunity, - denotes challenge)
Stakeholder Organisation Capacity

group
Government DFT - Need to prioritise coordination between government agencies to better understand what is
agency required, the roles and responsibilities and the capacities to ensure successful outcomes.
- Challenges within and between government agencies on access to data is a concern. For
example, DFT feel need to access Single Window to support EUDR, but unable to as is housed
in Customs Department
DMCR - Limited resources in RTG for much needed capacity development program.
- DMCR faces challenges linked to lack of staff and budget cuts
FTI - Once clarity is provided by EU then can better understand capacity gaps – it is clear there will
be challenges, especially for soya.
OAE - Smallholders, SMEs, and exporter companies have different challenges to meet due diligence
requirements. Technology and resources are lacking in government agencies to support robust
due diligence system, including monitoring.
RAOT - Clarity is needed on who is Thai government focal point.
RFD - Budget constraints are limiting the effectiveness of some agencies on implementation and
enforcement
- Laws are good, but enforcement is a challenge.
+/- Generally good availability of data (especially maps), but limited data on degradation.
TEFSO - Concern for all stakeholders and their awareness of EUDR and ability to meet the requirements
- It will take time and resources
Private sector Plan Creation - Numerous challenges on getting complete DDS for EUDR, will need support along supply chain.
Smallholder Rubber +/- Reliant on intermediaries for information, but also determining where will be the market for the
smallholder in rubber. If they decide to sell to a company trading to the EU, then will bring extra requirements
Songkla and costs. Smallholders have little say on where product is sold. Intermediaries have a lot of
control.
- Smallholders have access to limited resources to respond to market and legal demands
National NGO FGTBA - Need government agency to be appointed as focal point. They will then assess the capacity
needs of stakeholders and help coordination.
National NGO RECOFTC - Getting tenure through Kor Tor Chor is slow, linked to availability of resources and capacity gaps
Thailand - Capacities of CSOs to act as monitors and to support smallholders and SMEs
TEI - Clear challenges moving forward with state led initiatives that can support EUDR (incl. One Map
and Kor Thor Chor).
International Fern - CSOs will need support to ensure they can be effective monitors, including filing substantiated
NGO concerns with CAs.
84
The Forest Act draft of 2021 covers i. Palm oil, ii. Soybeans, iii. Cocoa, iv. Cattle, v. Rubber, and vi. Wood pulp.
https://www.congress.gov/bill/117th-congress/senate-bill/2950/text?r=2&s=2
46
RECOFTC - Numerous capacity issues for smallholders in existing supply chains.

Regional Office - Challenges for smallholders getting certification
International FAO FLEGT (ex- - Challenges for smallholders getting certification.

Organisation consultant) - Importance of intermediaries in supply chain, including information sharing.
3.2.5. Governance, legal frameworks, and other relevant initiatives
Table 17 Overview of the challenges and opportunities for EUDR implementation regarding governance, legal frameworks and national initiatives
raised by stakeholders in the workshops and interviews (+ denotes opportunity, - denotes challenge)
Stakeholder Organisation Others

group
Government DMCR + Legal framework is strong, supported by OneMap.
agency -Challenge is enforcement linked to budget cuts.
DNP +/- National laws are good, challenge is enforcement.
FIO + Working on CoC

+ Aim for 100% FSC certification for all wood plantations by 2025.
RAOT + Target of 2.88 million hectares certified by 2037
RFD + Legal frameworks are good, CF Act and efforts to develop CF can be a big help.
+ Khor Tor Chor and One Map are also important for helping to address encroachment in NRF
TEFSO + Good legal foundations for wood.
National NGO PFPC - Concerned about slow progress on VPA and implications for EUDR
+/- Conflicting laws will complicate process, however, One Map can support.
RNRF + EUDR synergies with initiatives of RTG
RECOFTC + EUDR can support addressing tenure challenges

Thailand +Progress under VPA, including TLAS.
WWF, Th + Kor Thor Chor has helped, its consideration of participation is important. There are still however
implementation challenges
International EU-ABC + RTG’s desire to conclude FTA with EU is strong motivation.

NGO - Frustration in ASEAN about EU’s approaches, including linked to REDII
GIA + / - Other initiatives in consumer markets need to be considered, if not then will become too
complicated
GPSNR + Legal framework and initiatives provide good foundations, but still numerous challenges
regarding implementation.
RECOFTC + Need to learn lessons from the legal reforms, including those linked to the VPA
Regional Office + Numerous initiatives on legal reform by government can benefit from EUDR.
- Complying with other national laws may be a challenge initially, especially as many in RTG are
not aware of the implications
+ / - Opportunities and challenges with many other legal initiatives from consumer countries and
blocs (e.g., ASEAN)
International EFI (Kuala + Great progress with VPA, and its help in strengthening the legal framework for timber.
Organisation Lumpur)
EFI (Thailand) + VPA has helped to strengthen the legal framework for wood supply chain.
FAO FLEGT + Great progress with VPA, good foundation in many ways.
(ex-consultant)
4.2.5.1 National initiatives
Many of those interviewed felt that the RTG has made considerable progress in recent years on strengthening the
legal framework for addressing deforestation and degradation. The starting point is the Thai Constitution (2017)
Section 43(2) and its emphasis that persons and communities shall “manage, maintain and utilise natural
47
resources, environment and biodiversity in a balanced and sustainable manner” and that the State shall (Section
57) “conserve, protect, maintain, restore, manage and use or arrange for utilisation of natural resources,
environment and biodiversity in a balanced and sustainable manner”. This foundation then percolates down to
ongoing legal reforms, including those based on the National Strategy (2018-2037)85 – specifically Sections 4.1.4
(Adopting monitoring technology to stop deforestation) and 4.5.5 (Providing a traceability system to reduce forest
encroachment and deforestation), as well as the Bio-circular Green Economy (BCG)86 model’s proposed policy
measures including (PM1) “Create digital repository of bioresources, cultural capital and local wisdom.” and (PM4)
“Transform the agricultural system”.
Recent initiatives include the impetus provided by the VPA, which was highlighted by many of the interviewees
from government and non-government organisations. The feeling was that the VPA process has created a stronger
legal framework that goes beyond wood. These efforts complement work by government agencies such as RAOT,
FIO and the NGO TEI to support certification in the country. These initiatives can provide a useful bridge for
engagement between the EU and RTG.
Some of the interviewees also commented on the EUDR’s consideration of “relevant legislation of the country of
production” (Article 2(28) of EUDR). Many of the interviewees touched on the legal framework for Land Use Rights
specifically relating to those living in NRFs, and the value of Kor Tor Chor in addressing the lack of clarity on the
issue. This is particularly important considering the estimated 2.1 million ha of plantations in NRF, of which 1.1
million ha are EUDR commodities (Table 5). However, one anonymous respondent also raised the concern that
prejudices continue to exist in the treatment of forest peoples, especially ethnic minorities (also known as Hill
Tribes). The respondent felt however that the EUDR’s recognition of FPIC could help to strengthen the
environment for these peoples, including if FPIC can be integrated into relevant national laws, and also into the
operations of companies.
The interviewee from TEFSO highlighted that one barrier to the finalisation of the VPA was issue of labour rights
– specifically related to children of plantation workers and owners working in the plantation, as well as the labour
rights of plantation workers. The issue of labour rights and human rights have been flagged by various
organisations working on labour rights87. Investigations and reports by NGOs have also highlighted challenges
facing migrant workers particularly forced labour and trafficking, this is a problem in the fishing industry, with
authorities in the USA taking particular interest in the problem with the country being on the Tier 2 Watchlist in
2021, but last year it moved back to Tier 2. Labour rights have also been exposed in the agricultural sector88.
4.2.5.2 ASEAN initiatives
There is a clear opportunity for the EU to build on existing and planned initiatives within ASEAN recognising the
large level of intra-regional trade, including in forest risk commodities, as well as work to increase cooperation
within the region.
Within the areas of ASEAN cooperation, the Thai government has agreements in agriculture and forest activities
such as ASEAN Agreement on Transboundary Haze Pollution, ASEAN Criteria and Indicators for Sustainable
Management of Tropical Forests, and ASEAN Criteria and Indicators for Legality of Timber. There are also various
ASEAN level decision making and implementation bodies such as ASEAN Ministers Meeting on Agriculture and
Forestry (AMAF) and the Senior Officials Meeting of The ASEAN Ministers on Agriculture and Forestry (SOM-
AMAF). These can play a key role in enhancing intra-ASEAN cooperation on EUDR implementation, one specific
example is the Vision and Strategic Plan for ASEAN Cooperation in Food, Agriculture and Forestry (2016-2025)89,
which defines the shared vision and goals for bloc for the agriculture and forestry sectors, with priorities for
cooperation. The Vision and Strategic Plan directly and indirectly covers issues that are relevant to the EUDR:
85
https://www.sme.go.th/upload/mod_download/download-20201012111719.pdf
86
https://www.bcg.in.th/eng/strategies/
87
https://labourrightsindex.org/lri-2022-documents/lri-2022-final-7-oct.pdf
88
https://www.reuters.com/article/us-thailand-workers-migrants-idUSKCN1PI07N
89
https://asean-crn.org/vision-and-strategic-plan-for-asean-cooperation-in-food-agriculture-and-forestry-2016-2025/
48
• Strategic Thrust 1. Enhance quantity and quality of production with sustainable, ‘green’ technologies,
resource management systems, and minimise pre- and post- harvest losses and waste
• Strategic Thrust 5. Assist resource constrained small producers and SMEs to improve productivity,
technology, and product quality, to meet global market standards and increase competitiveness in line with
the ASEAN Policy Blueprint on SME Development
• Strategic Thrust 6. Strengthen ASEAN joint approaches on international and regional issues affecting the
FAF sector.
Additionally, the guiding principles of the ASEAN Regional Guidelines for Sustainable Agriculture in ASEAN90,
which were adopted by ASEAN Ministers on Agriculture and Forestry (AMAF) in October 2022, includes emphasis
on “Conserving, protecting, enhancing natural ecosystems, promoting and enhancing nature resources and
communities”, with the Guidelines going onto emphasise in its Key Strategies ““Discouraging and disallowing any
further clearing of primary jungles, mangrove areas, peatlands, and other areas deemed environmentally
valuable.” While there is concern on the practicalities of ASEAN level commitments and guidelines, they are
developed with the input and consent of the ASEAN Member States, reflecting their desire and commitments to,
in this case, halting deforestation from conversion to agriculture.
One of the interviewees from RECOFTC suggested the need for the EU to link with ASEAN bodies as they work
to develop the Vision and Strategic plan for the next phase which starts in 2025.
The Single Window in Thailand is being set up to provide a national gateway to facilitate information exchange
within and between government agencies and the business sector in relation to the import, export and logistics
including international cross-border data and information sharing between Thailand and other countries. It was
referenced as being potentially useful for supporting the EUDR. The lead government agency is the Customs
Department (Ministry of Finance). The Single Window is in line with the ASEAN Agreement to establish and
implement the ASEAN Single Window.
The EU’s relationship with ASEAN appears to be on a good footing, the two blocs have been dialogue partners
since 1997. In 2020 ASEAN and the EU elevated their relations to the level of a Strategic Partnership and have
various initiatives including ASEAN-EU Dialogue on Sustainable Development. During the 3rd ASEAN Dialogue
on Sustainable Development November 2021 Green Team Europe and ASEAN launched an initiative aiming to
strengthen relations between the two blocs on “climate action, environmental and biodiversity protection, clean
energy transition, disaster resilience, prevention of illegal logging, wildlife trafficking and air pollution.”91 The initial
budget for the initiative is €30 million.
The EU has also been a development partner at the regional and national levels. For instance, during the period
2014-2020 the EU provided support through various means to the ASEAN Secretariat, supporting ASEAN
Regional Integration including through funds of over €250 million. Additionally, the EU has provided bilateral
support of €2 billion to ASEAN Member States during the same period92.
4.2.5.3 Other initiatives
Some of those interviewed reflected on the need for the EU to ensure that the EUDR synergises with other
initiatives by the bloc, its members states and other consumer and processing countries. This included references
to the development of a FTA between the EU and Thailand. Reference was also made to EU initiatives such as
the Corporate Sustainability Due Diligence Directive (EU-CSDDD) and Renewable Energy Directive II (REDII),
regulatory efforts in EU members states including France with its Law on the Corporate Duty of Vigilance and
Germany with its Act on Corporate Due Diligence Obligations in Supply Chains, as well as in other consumer
90
https://asean.org/book/asean-regional-guidelines-for-sustainable-agriculture-in-asean-developing-food-security-and-food-productivity-in-asean-
with-sustainable-and-circular-agriculture/
91
https://ec.europa.eu/commission/presscorner/detail/en/IP_21_6111
92
https://www.eeas.europa.eu/asean/european-union-and-
asean_en?s=47#:~:text=The%20EU%20and%20the%20Association,as%20free%20and%20fair%20trade.
49
countries such as the UK (Environment Act) and USA (proposed Forest Act, as well as the New York Tropical
Deforestation-free Procurement Act).
The FLEGT VPA understandably featured prominently among many of those interviewed, particularly for those
that have been involved in the process. There was a desire from several individuals interviewed that the VPA
should continue, feeling that the requisite systems are nearly complete – e.g., TLAS – and these would
complement the EUDR. However, clarity was sought on the benefits to finalising and signing the VPA considering
the time and resources required, and if the FLEGT licences were not sufficient for the EUDR. It was recommended
that the EU is clear on understanding on why some stakeholders wish to continue with the VPA in its present form,
having clarity on the costs and benefits of doing so. As one of the interviewees put it that EU should keep in mind
the importance and meaning of the P in the VPA, and what it would signify if the VPA was arbitrarily dropped by
the EU without understanding the motives of those that wish to finalise the process.
RECOFTC in their workshop on 8th February initially shared that they hoped the VPA should continue in Lao PDR,
Thailand, and Viet Nam – as they felt it provided an opportunity to immediately address some of EUDR relevant
issues. In a follow up interview with some RECOFTC staff they suggested that if the EU works immediately to 1.
raise awareness of the EUDR in Thailand and 2. Has clear plans to work with RTG on creating a national focal
point then there is no need for the VPA. The rationale for this and for why Thailand should be well placed for the
EUDR is that the RTG has made considerable progress in addressing deforestation and degradation – there is
clear commitment. According to RECOFTC many in Thailand recognise the need to have resilient systems in place
to address trade in any commodity that may have been produced resulting in deforestation, degradation, or
illegality. Thailand should not need to rely on the EU for this, it should be developed by the RTG.
4.2.5.4 Governance
Discussions on issues related to governance were raised by various representatives from civil society. For
example, enforcement of the EUDR would, to a certain extent, rely on watchdogs – including CSOs - in the
producer countries, for example, reporting on actors that may be undermining the Regulation. These kinds of
watchdogs often face challenging operating environments, including in Thailand93. The challenges facing domestic
civil society organisations is also acknowledged in the analysis by CIVICUS94 which categorises Thailand as
”repressed”, where ”Civic space is significantly constrained. Active individuals and civil society members who
criticise power holders risk surveillance, harassment, intimidation, imprisonment, injury, and death. Although some
civil society organisations exist, their advocacy work is regularly impeded, and they face threats of de-registration
and closure by the authorities.”
The importance of these independent watchdogs is underlined by the potential issues that may arise by weak
enforcement of Thai laws by government agencies. These enforcement challenges may emanate from, for
example, reduced budget for these agencies. A recent example is the budget cut for the DNP during 2020 - 2021
(US$17.66 million), with one result being a reduction in the number of forest rangers from 5,163 to 3,432, and
significant pay cuts for those that remained in their jobs95. In May 2023 the Ministry of Finance put forward a
proposal for forest rangers to have a pay rise from 9,000 Thai baht (roughly US$262) to 11,000 Thai baht a month
(roughly US$321), according to the report the last pay rise the rangers received was in 2013 (from 6,000 Thai baht
[roughly US$175])96. The income from the forest rangers should be considered in the context of the fact that in
2022 the minimum wage in Thailand was just over US$217, and average monthly wage in that year was
approximately $450 a month. The DNP has also recently been hit by a significant corruption scandal, with the
Department’s Director-General being arrested for graft9798. The scandal not only affects the DNP, but also
undermines confidence in national efforts to address corruption – the National Anti-Corruption Commission had
93
https://www.reuters.com/article/uk-thailand-rights-activist-idAFKBN1320YB
94
CIVICUS. (2021). Monitor: Tracking conditions for citizen action. https://monitor.civicus.org/
95
https://www.thaipost.net/politics-news/67695/
96
https://www.thaipbsworld.com/pay-rise-sought-for-thailands-forest-
rangers/#:~:text=The%20Department%20of%20National%20Parks,effective%20from%20October%201st.
97
https://news.mongabay.com/2023/01/corruption-scandal-in-thai-parks-agency-has-far-reaching-impacts-activists-say/
98
https://bkktribune.com/editorial-systematic-corruption-needs-systematic-anti-corruption-reform_and-accountable-politics/
50
given the DNP a perfect score 100/100 in the last 3 years on its handling of corruption issues raised about
corruption in the DNP, which makes the recent scandal even more concerning.
The EU has been providing support to civil society in Thailand for many years, including to develop their capacity
to participate in VPA negotiations and support monitoring. The hope from some from civil society was that this
support would continue, especially as the previous support had proven to be effective.
3.2.6. Definitions
An issue that came up in a few interviews and in the workshops was the inconsistencies in definitions in Thailand
that may create challenges for supply chain actors, and operators and traders to meet EUDR requirements.
Defining Forests
Participants in the 17th of February workshop raised the issue of the need to understand any problems that may
arise on difference in definitions of forests within Thailand. The question was also raised by RECOFTC Thailand
in the interviews. The suggestion from the Department of Trade Negotiations was that discussions should be held
with the EU to urgently address this, one of the interviewees from RECOFTC felt that the priority was for Thailand
to ensure there is consistency in its definition. The representative from DG Environment pointed out that the EUDR
is clear on this issue.
According to the Forests Act, B.E. 2484 (1941) “Forest” means land claimed by no one, according to the law on
land99. While the National Reserved Forests Act, B.E. 2514 (1971) states that “Forest” means land including
mountains, creeks, marsh, canals, swamps, rivulets, waterways, lagoons, islands, and seashore areas that no
one has obtained under the law.100 Finally the National Forest Policy (2019) defines Forests as lands with
vegetation cover which can be classified as tree cover and with an area of more than 0.5 hectares, and includes101:
1. Land which has temporary trees due to the clear-cutting forest management activity, but can have the
species regeneration within 5 years, or more than 5 years in the case of special characteristics area
based on the academic reason and it expect to have vegetation cover capability which can be classified
as tree cover and with an area of more than 0.5 hectares.
2. Forest road, firebreaks and small open space caused by adherence to scientific guidelines on forest
management activities, it does not include the roads with have main objective for transportation.
3. Tree cover area in strip or in row with an area of more than 0.5 hectares, and the area width is more
than 20 meters.
4. Mangrove forest in the tidal area, regardless of whether the area has been classified to land area or
not, it includes the freshwater swamp forest and other relevant forest types.
5. Bamboo covered area
6. It includes rangeland and vegetation on natural rock platform which surrounding with forest areas.
7. Other issues outside the forest definition in context of preceding conditions, need to consider the forest
definition of FAO Global Forest Resources Assessment 2020.
Forests do not include eucalyptus plantations and the tree cover areas in which the main production is not logs,
for example, agroforest area, orchard, rubber plantation and palm oil plantation102.
Regardless of the EUDR it would clearly be of benefit if there is a universally agreed and used definition of what
constitutes a forest in Thailand.
99
https://www.krisdika.go.th/data//document/ext809/809910_0001.pdf
100
https://www.krisdika.go.th/data//document/ext810/810048_0001.pdf
101
https://4occ.isoc.go.th/km/?p=3608
102
https://www.forest.go.th/land/category/%E0%B8%AA%E0%B9%88%E0%B8%A7%E0%B8%99%E0%B8%AA%E0%B8%B3%E0%B8%A3%E0%B
8%A7%E0%B8%88/%E0%B8%A3%E0%B8%B2%E0%B8%A2%E0%B8%87%E0%B8%B2%E0%B8%99%E0%B9%82%E0%B8%84%E0%B8%A
3%E0%B8%87%E0%B8%81%E0%B8%B2%E0%B8%A3%E0%B8%88%E0%B8%B1%E0%B8%94%E0%B8%97%E0%B8%B3%E0%B8%82%E0
%B9%89%E0%B8%AD%E0%B8%A1/
51
Defining deforestation and forest degradation
In Thailand deforestation is defined as the decrease of forest area caused by human activities i.e., logging, forest
encroachment, forest fire, land use conversion from forest area to other areas and its impact the ecological
services and the major function of ecosystem for example wildlife habitat, biodiversity, water flow control and
carbon cycling47.
The National Reserved Forests Act, B.E. 2514 (1971) states forest is degraded when it is abandoned plantation,
or if the forest contains few valuable trees and it is difficult to revive to its natural state. MNRE have further guidance
through criteria and indicators to help determine if a forest is degraded: The criteria and indictors are found in RFD
Regulation regarding Permission for forest plantation establishment or tree planting within NRF (2005)103 and three
Cabinet Resolutions on 2nd September 1986, 2nd June 1987 and 9th May 1989.
103
https://forestinfo.forest.go.th/pfd/Files/FileEnactment/ET6.pdf
52
3.3. Potential impacts of the proposed Regulation in Thailand
3.3.1. Potential Impacts - Addressing deforestation and degradation in Thailand
As shown in sections 4.1.2.1 and 4.2.1, Thailand has made considerable progress in addressing deforestation in
recent years. This brings further emphasis to the question raised by some of those interviewed - what is the value
of the EUDR for Thailand? The importance of this question was usually set against the concern of the perceived
costs - especially for smallholders.
The question of the value of the EUDR for Thailand is partly answered by the fact that deforestation and
degradation still occurs in Thailand, even though it is on a much smaller scale than before - an estimated 49,102
ha of forests were lost during the period January to March 2021 to January to March 2022 (Figure 5a). One of the
respondents from RECOFTC stated that while conversion to agriculture is a small issue nowadays, if the RTG
takes the lead in setting up a resilient DDS it can help to ensure it does not flare up again. The respondent went
on to say that Thailand should be presenting itself in a positive light, as in legal terms it meets many of the EUDR
requirements and has many supporting systems and commitments in place. The feeling was that the RTG should
be proactive in their engagement with the EU (considering the willingness of the EU to engage on this as shown
in e.g., Article 29 and 30 of the EUDR). This would be beneficial in getting the EU’s support in addressing the
gaps, it may also help in the FTA negotiations, as well as give Thailand a competitive advantage. The EUDR’s
value should also be considered in helping to reduce Thailand’s deforestation footprint overseas.
The impact of the EUDR may increase if additional commodities are included, something that OAE feel is likely to
happen within two years. Thailand’s also produces a large amount of non-EUDR agricultural commodities that
have been linked with deforestation including cassava, maize and sugar cane (see annex 8). Thailand not only
imports a large amount of EUDR commodities (see annex 6), but also imports commodities that may in the future
be included in the EUDR including from countries suffering from forest conversion (see section 4.2.1).
3.3.2. Potential impacts - Smallholders

There is a feeling that EUDR stakeholders in Thailand are already playing catch up on the EUDR. The sense
among some of those interviewed was that there are some substantial information gaps, which feel particularly
acute considering the tight timetable. The concern was that some supply chain actors are better placed than others
to access the information and respond, and that many smallholders were not well placed. There are various
communication mechanisms that are available, including local government agencies, intermediaries, and larger
companies, but the worry was that those in remote areas would be less well served than those concentrated in
the main production areas (see figure 6a-d for an illustration of this).
There was universal concern among those interviewed of the potential impacts on smallholders, this is set against
the often precarious nature of the livelihoods for many smallholders in the country. For example, the interviewees
from Green Invest Asia (GIA) emphasised the fact that rubber smallholders are often being adversely affected by
market fluctuations, a view supported by academic research104 and work by organisations such as the World
Bank105. For instance, the price of rubber (ribbed smoked sheet - RSS3) on the world market has fallen from
US$/kg 3.7 in 2010 to US$/kg 1.8 in 2022, with most recent data from May 2023 has the value at US$/kg 1.56 106.
On the other hand, the prices for most of the other EUDR commodities have increased in recent years – with palm
oil increasing by 112% between 2019 and 2022. Additionally, the production costs (e.g. fertiliser and fuel) have
also seen significant increases in the last few years. The fluctuation in prices that smallholders can get for their
104
Andriesse, E., & Tanwattana, P. (2018). Coping with the end of the commodities boom: rubber smallholders in southern Thailand oscillating
between near-poverty and middle-class status. Journal of Developing Societies, 34(1), 77-102.
https://journals.sagepub.com/doi/abs/10.1177/0169796X17752420?journalCode=jdsb
105
World Bank Group. 2022. Thailand Rural Income Diagnostic: Challenges and opportunities for Rural farmers. World Bank, Bangkok.
https://www.worldbank.org/en/country/thailand/publication/thailand-rural-income-diagnostic-challenges-and-opportunities-for-rural-
farmers#:~:text=The%20report%20identifies%20three%20key,3)%20improving%20access%20to%20markets.
106
https://www.worldbank.org/en/research/commodity-markets
53
products, should also be considered in the context of changes in production costs (e.g. fertiliser and fuel) that have
increased in the last couple of years. On top of this their livelihoods are also being impacted by climate change.
GIA provided further details on some of the challenges facing rubber smallholders including that commercial rubber
tapping usually starts seven years after trees are planted. Another consideration is that rubber many smallholders
also often face challenges marketing their latex due to their weak bargaining power, with this often being
exacerbated by the fact that many have limited income diversity, with the result being that many farmers earn less
than the minimum wage from their land107. This has led to RFD and RAOT supporting income diversity
programmes centred around agroforestry systems based on rubber.
The respondent from GPSNR, however, felt that the rubber sector in Thailand was in many respects quite well
placed in meeting the demands from the EUDR, and in fact it may have a competitive advantage when the
Regulation comes into force compared to other rubber producing countries, such as Indonesia and Malaysia. This
reflects the geographical concentration of many of the supply chain actors, especially smallholders. With those in
this area having good access to the market and support services. The respondent noted, however, that there are
some rubber smallholders in Thailand located in remote areas with limited access to these services, and they may
find themselves at further disadvantage from the EUDR, including access to information and support to meet its
requirements. This was echoed by research from EFI who concluded that smallholders may be excluded from the
EU market as traders focus on low-risk suppliers that are more able to comply with DDS.
The smallholders that were interviewed as part of the assessment all strongly emphasised the need to get more
information on the requirements of the EUDR, and clarification on roles and support from the government and
intermediaries, as well as from the EU, in understanding the compliance requirements, and associated costs. The
smallholders were concerned the numerous costs of getting certification, and the few benefits would also apply
for the EUDR.
The costs, including time, for the smallholders and SMEs to adhere to, for example, due diligence requirements
need to be considered. A briefing from the European Parliamentary Research Service stated that “Depending on
the complexity and risk associated with deforestation of the operator's supply chains, setting up the due diligence
system would involve one-off payments of between €5,000 [US$5440] and €90,000 [US$97,900]”49. These costs
would include collection of geolocation coordinates for all land plots where the commodities were grown. The
concern, for example from EFI Thailand, was that the smallholders would be the ones that have to bear these
costs. Again, one also needs to keep in mind the different level of challenges according to the location of the
smallholders, considering market access, location of support centres, mobile network access (which is a particular
challenge in large pockets in the north of country108) as well as distance from their holding to a sealed road.
All stakeholder groups interviewed flagged the challenges faced by smallholders to meet requirements for getting
certification and being able to cover the costs raising the concern that these challenges are relevant to the EUDR
compliance. This was set against the challenges they faced to get a reliable income from their products from their
smallholding.
The concern about risks to smallholders has been briefly explored by research on palm oil smallholders in
Indonesia, the findings are also relevant for smallholders in Thailand. The main concern was costs and
coordination for smallholders to meet the due diligence requirements. However, some stakeholders, including the
Indonesian Palm Oil Farmers Union recognise the risks, but also the opportunities provided by improved
traceability systems, as well as possible technical and financial support for smallholders, and possibilities to
address grievances109. This was also raised in some of the interviews – including that increased transparency in
the supply chains may help to shine a light on the challenges facing smallholders regarding making a sustainable
income from their landholdings, strengthen their tenure rights, increase understanding of the roles of
intermediaries, and improve information access for smallholders.
107
https://www.earthworm.org/news-stories/guideline-rubber-agroforestry-thailand
108
https://www.nperf.com/en/map/TH/-/1885.dtac/signal/?ll=15.244146091407055&lg=95.95458984375001&zoom=6
109
https://www.cnnindonesia.com/ekonomi/20230113142538-92-900061/petani-kritik-keras-ri-malaysia-ancam-setop-ekspor-sawit-ke-eropa
54
The concern for smallholders’ compliance, was also shared by many of the international and national NGOs and
international organisations who felt that one of the unintended consequences of the EUDR may be the creation or
increased differences between groups of smallholders. In this case there would be two tiers of smallholders:
• Tier 1 would be those that are more able to meet the EUDR’s requirements through their better integration
in the supply chain and good access to information and support which would be based on their connection
to infrastructure. The first tier would more likely get a premium for their rubber latex.
• Tier 2 would be comprised of those that are in more remote areas (including in NRF). They would be more
challenged to meet EUDR’s requirements, they would likely not have the price premium, while having the
same production costs or higher due to their location, this may force them to turn away from rubber
production, but also it may force them to seek income from surrounding forests, especially in times of
adversity.
An additional concern was the tight timetable for the EUDR coming into force will further emphasise this problem
– GPSNR shared that they had anecdotal evidence that this was already happening in the rubber supply chain in
Thailand.
The issue of impacts on smallholders needs to also consider the availability of data, including regarding
smallholders growing the EUDR commodities in NRF. While Thailand is proactive in its data collection and
management regarding many of the issues linked to the EUDR, as demonstrated by the data shared in this report,
there are however numerous data gaps that should be addressed, not only considering the needs of the EUDR,
but also for addressing Thailand’s national commitments and programs.
While there is universal support for placing transparency at the heart of the EUDR, including making the
information submitted by the operators and trader publicly available, there was concern of the risks of how the
data could be used by government agencies to investigate smallholders that may not comply with the EUDR, of
that it may facilitate land grabbing. One of the interviewees from RECOFTC wondered what safeguards the EU
would put in place on how the data shared was used, for example if some of the data submitted by smallholders
could be redacted.
3.3.3. Potential impacts - SMEs
Many of those interviewed also highlighted the possible negative impacts of the EUDR on SMEs in the different
supply chains. SMEs play a key role, including being intermediaries buying and transporting the product from the
landholding to the processing plant, as well as playing a key role in information sharing with smallholders.
The general concern was that SMEs may be cut from the supply chains as their buyers strive to minimise the risks.
A result may be that some SMEs that will be able to meet EUDR requirements will as a result have access to the
EU market and other markets, while those that are unable to meet the requirements will have a reduced market
with implications for their income. The interviewee from EFI Thailand highlighted that SMEs dominate the wood
supply chain in Thailand– around 80%. However, few of these SMEs have a wood processing licence as it is very
time consuming and expensive to get the necessary permits. This could then push SMEs out of the legal wood
supply chain.
A concern was also raised in the interviews about SMEs’ access to information recognising the tight timetable for
when the EUDR comes into force. As with smallholders there was a concern that awareness among SMEs is
limited, and they need to start preparing as soon as possible. This will of course have implications for their
capacities, including understanding their capacity needs and putting forward a program to address these.
As highlighted in section 4.2.3 a few of those interviewed were concerned that some of the SMEs, especially
intermediaries, may pushback against the increased transparency in the supply chains. This concern needs to be
better understood, and while it can be mitigated through having clear safeguards in place on how propriety data
is shared, it will also require a significant awareness raising program to address these concerns.
WWF Thailand was concerned that the EUDR will create another market barrier for SMEs, ultimately larger
companies will be favoured. If SMEs are less exposed to the EU market, then they will have time to adjust, but if
55
they are part of the EU supply chain then they may not have the capacity and resources to adapt in a timely
manner, including moving to non-EU supply chains.
3.3.4. Possible impacts of benchmarking
The interviewees from GIA raised the concern that if supply chains from high-risk countries will require more
comprehensive due diligence systems compared to those based in low-risk countries and are more likely to be
checked by CAs, the result may be that companies may shift their supply chains to the low-risk countries. EU-ABC
echoed this saying that countries like Cambodia and Lao PDR will face more challenges than Thailand to have
national systems in place to support EUDR due diligence requirements. This returns to one of the findings of the
Fitness Check of the FLEGT and EUTR Regulations – that costs for meeting due diligence requirements for the
EUTR are only significant if timber is imported from high-risk countries.
The expectation from many of those interviewed, especially from government agencies, was that Thailand would
be categorised as low risk when the benchmarking is updated no later than 18 months after the EUDR comes into
force (Article 29(2)). This expectation needs to be carefully managed in the benchmarking process. The concern
was that if Thailand would be classified as standard it would likely be frustrating for many government agencies.
The expectation for Thailand’s low risk classification is based on the perception that it is effectively addressing
domestic deforestation and degradation, and the fact that it has made considerable progress with the VPA.
However, issues were raised by the interviewees that may result in standard classification:
• Thailand’s deforestation footprint beyond its borders
• “Production trend of relevant commodities and of relevant products” (Article 29 (3c)) and the country’s
drive to expand palm oil production (though not increase the land under cultivation)
• Ability of “NGOs, and third parties, including indigenous peoples, local communities and civil society
organisations” to provide information (Article 29 (4a))
• Availability of relevant data, and the “existence, compliance with, or effective enforcement of laws
protecting human rights, the rights of Indigenous Peoples, local communities and other customary rights
holders” (Article 29 (4d))
• Imports of EUDR and non-EUDR commodities from Myanmar in relation to (Article 29 (4e) “sanctions
imposed by the UN Security Council or the Council of the European Union on imports or exports of the
relevant commodities and products” (see annex 6 for overview of imports of EUDR commodities from
Myanmar).
It may also be a concern that operators may also consider the implications of the categorisation of a country as
high risk compared to low risk and the requirements for more checks by CAs in the EU member states as a result.
Furthermore, some (e.g., DNP) also flagged the ability for producers and traders to move their markets where
there is continued demand and less reporting requirements, such as China and India, if it was felt that the EUDR
was too onerous and did not bring clear benefits. While the EU is an important market for Thailand (Table 12), its
main markets for all the commodities lie outside of the EU (also see annex 6). GIA, EFI (Thailand) felt that traders
and operators may focus on sourcing from clean supply chains for exports to the EU and continue to source from
high-risk sources for exports to non-EU markets. One of the respondents highlighted in a follow up email that the
EU needs to urgently and constructively engage with governments in producer countries – if not then the risk is
that these countries will encourage producers and traders to switch their market focus. While some may question
the ease with which this would happen, the respondent felt that there would likely be short term disruption to supply
chains, as some traders may try to import commodities to the EU before the EUDR comes into force, but also be
a drop in imports soon after, particularly for supply chains where meeting the due diligence requirements will prove
to be challenging.
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3.3.5. Potential impacts of ending VPA process
Thailand is currently in negotiations with the EU on the FLEGT VPA. It is one of the 13 countries that is involved
in the VPA process. Thailand and the EU formally started the VPA process in 2013, with the first official
negotiations taking place in June 2017.
The VPA is notable for various reasons, including the development of the TLAS, facilitating increased cooperation
between different agencies in the EU and Thailand working on forestry, as well as its emphasis on multistakeholder
processes. The VPA has also been a conduit for funds from the EU and other donors for CSOs, timber associations
and SMEs. For example, RECOFTC has worked to support the Thai government to provide clear guidelines on
harvesting of timber from smallholder and community plantations on public lands, and has also worked, with funds
from FAO FLEGT110, to develop the capacities of smallholders and SMEs to ensure they can participate in the
VPA processes and adhere to the requirements, including the TLAS.
The interviewees with direct links to the timber sector were aware of the VPA, and highlighted the value of the
VPA process. This includes in the supporting the RTG in establishing the TLAS, creating shared understanding of
the need to improve controls for legality in supply chains, and strengthening multi-stakeholder processes in the
forest sector. There was a clear sense of pride among some of the VPA stakeholders in the interviews with the
achievements of the VPA. Some of the respondents raised the urgent need for the EU to clarify the next steps for
the VPA. FAO FLEGT and some of the respondents from RECOFTC, for example, flagged that if the VPA process
is ended before agreement is officially reached there may be implications - it could affect commitment to EUDR
and morale of some of those that had invested a great deal in the VPA process. The FAO FLEGT respondent
emphasised the consideration of the P in the VPA – that is the EU summarily ended the VPA and / or poorly
communicated then this may affect relations moving forward. One of the respondents urged the EU not to
undermine the goodwill created by the VPA by summarily ending it, the suggestion was to proactively engage as
early as possible with RTG on the ways forward, including in openly assessing the costs and benefits of trying to
conclude the negotiations, and reflecting on the lessons learned and their implications for the EUDR.
One of the respondents from RECOFTC recognised the importance of Thailand finalising all the components of
the VPA, regardless of if the Agreement would be signed or not. This is based on the view that the complete VPA
components would be of practical and symbolic value to Thailand. They did also recognise the limited resources
and time to meet the EUDR’s requirements and conclude the VPA, this was set against the background of the
actual value of a signed VPA in the new EUDR world.
FGTBA felt that EU missed an opportunity by ending funding for TEFSO as they would have been well placed to
support national coordination and awareness raising of EUDR, this means that there have been delays in
information sharing which may become more of an issue considering the tight timetable, the recommendation was
to recognise and build on the solid foundations created by the work of TEFSO, including securing funding for its
continued work to help coordinate EUDR awareness raising.
3.3.6. Other potential impacts
The issue of potential disruption to supply chains may be a concern at the 18- and 24-month milestones – as
operators may wait to see how the EUDR is enforced once competent authorities (CAs) are starting to conduct
checks. The disruption may cause delays as operators wait to see how the pioneer shipments are met as they
enter the EU market and CAs get their systems up and running.
One RFD official felt the EUDR is too much stick, and should be more carrot, including through providing financial
support to government agencies for forest protection and restoration, helping it to achieve its forest area target.
This goes further as some of the respondents felt that the EUDR is not being developed and communicated in a
participatory manner. In some cases, it was felt that the EU was taking a path that reflected colonial thinking. This
is amplified in the concern raised by OAE, for example, that the EU is using the EUDR as a mechanism to protect
its own industries, but also that the EU is not giving producer countries time to make the appropriate preparations.
110
https://www.fao.org/in-action/eu-fao-flegt-programme/our-projects/ru/#/web/country/THA
57
Finally, the concern raised by DTN, questioning the spirit of the EUDR – sharing the feeling that it is not compatible
with the WTO, and it would undermine efforts to meet the SDGs, appears to have more traction Indonesia and
Malaysia, but could grow, if not in Thailand, then at the ASEAN level.
This was further emphasised by TEI, for example, who sought clarity on if meeting EUDR would bring benefits for
smallholders, specifically, and the producer countries in general. This can be taken in the context of the questions
of benefits to countries completing the VPA, meeting all EU’s requirements but with limited economic return – with
RECOFTC’s regional office raising the question of the financial benefits of Indonesia getting access to the “Green
Lane” with FLEGT licences.
Furthermore, there was also concern that if the costs of the EUDR are proving high then this could undermine
goodwill toward the EU, not only impacting the EUDR but also other sustainability initiatives, as well as the
negotiations for the FTA.
Finally, there was a feeling that the EU needed to return to the rationale for the EUDR in their communication –
especially the increasing climate emergency and the desire of the EU to address it in the spirit of partnership.
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4. WAYS FORWARD
4.1. Stakeholder analysis
The many challenges and opportunities, as well as the potential impacts of the EUDR presented in sections 4.2
and 4.3 emphasise the need for a systematic program to help ensure the trade of the seven commodities from
Thailand to the EU meets the EUDR’s objectives. A stakeholder impact analysis provides a good starting point to
develop the program to effectively engage and support the EUDR’s key stakeholders in Thailand to ensure it
achieve its outcomes, while addressing the risks. The analysis includes identifying the stakeholders, the potential
impact of the Regulation on them and their ability to influence its implementation. Focus here is on non-state actors
(Table 18). While the analysis is simplified it does however provide a basis for identifying the ways forward laid
out in section 4.2. The analysis for the SAs focuses on their responsibilities in the context of the EUDR (Table 19).
Table 18 Impact analysis of EUDR on Non-State Actors
Stakeholder group Potential impact of Ability to support Strategy to engage and support
EUDR on them* and/or hinder EUDR
success**
Smallholders -- - Awareness raising
Complement existing tools and initiatives to
support adherence
Opportunity to participate in CD programs
provided by NGOs and SAs
SMEs -- - Awareness raising
Complement existing tools and initiatives to
support adherence
Private sector – Thai - - Awareness raising
companies Opportunity to participate in CD programs
Private sector – Operator - O Awareness raising
/ trader Opportunity to participate in CD programs
Intermediaries -- - Awareness raising
National NGOs + + Awareness raising
Request for proposals (RfP) for support for CD
program supporting SA and NSAs (particularly
smallholders and SMEs)
Capacity development support and resources
for monitoring EUDR implementation and
supporting enforcement (e.g., through
Substantiated concerns)
International NGOs + + Awareness raising
RfP for support for CD program supporting
national SA and NSAs (including at ASEAN
level)
59
Certification body ++ + Awareness raising
Farmer cooperatives + +/- Awareness raising
National Farmers + +/- Awareness raising

Council
Trade Associations + + Awareness raising
* Significant positive impact = + +, Slight positive impact = +, Slight negative impact = -, Significant negative impact = - -. Neutral =
O
** Significant potential to support = + +, Slight potential to support = +, Slight potential to hinder = -, Significant potential to hinder = -
-, Potential to both support and hinder = + / -
Table 19 EUDR commodity related government organisations and their main responsibilities in context of EUDR
Ministry Department Responsibilities in context of EUDR (including)

Ministry of Natural Royal Forest Department RFD is responsible agency for managing NRF.
Resources and (RFD) RFD is the main coordinating agency in Thailand on FLEGT related matters.
Environment (MNRE) RFD is home to TEFSO.
RFD oversees data management for forests in the country
Department of National DNP is responsible for managing protected areas, such as national parks,
Parks, Wildlife and Plant forest parks, wildlife sanctuaries, non-hunting areas, botanical gardens, and
Conservation (DNP) arboretum.
DNP is the focal point for REDD+.
Thai-EU FLEGT Secretariat TEFSO provides secretarial and technical support for the Thailand-EU FLEGT
Office (TEFSO) VPA process, this includes coordinating with the relevant Thai and EU
authorities and disseminating information about FLEGT VPA 111. TEFSO is
under RFD.
Forest Industry Organisation FIO, a state enterprise under MNRE, is responsible for managing forest
(FIO) plantations on behalf of the public. FIO administers 177,280 hectares of forest
plantations.112 Most of the plantations are located within NRF.
The Department of Marine DMCR is responsible for management of mangrove forests, wetlands, marine
and Coastal Resources and coastal ecosystems.
(DMCR)
Ministry of Agriculture Rubber Authority of Thailand RAOT is mandated to administer and support the management of rubber in
and Cooperatives (RAOT) Thailand, including promotion of the country as a rubber manufacturing hub113.
(MOAC)
Department of Livestock Create added value and marketing livestock products
Development (DLD)
Office of Agricultural Prepare and manage agricultural information

Economics (OAE) Prepare reports on the agricultural economic situation both within the country
and abroad.
Department of Agricultural Oversees Farmer book (also known the Green Book as part of the e-Farm
Extension (DAE) system)
National Bureau of Oversees Thai Agricultural Commodity and Food Standards, and Thai
Agricultural Commodity and Agricultural Standards
Food Standards
Cooperative Promotion Oversees development and management of farmer cooperatives

Department (CPD)
Ministry of Commerce Department of Foreign Trade Is the main regulatory agency overseeing imports and exports.
(MOC) (DFT) Enforces trade and customs administrative requirements
111
https://tefso.org/en/flegt/
https://www.fio.co.th/fioreport/2561.pdf
113
https://www.raot.co.th/raot_en/ewt_w3c/ewt_news.php?nid=1214&filename=index
60
Department of Trade Responsible for bilateral and multilateral trade negotiations

Negotiations (DTN)
Department of Internal Trade Home to the National Palm Oil Policy Committee
Ministry of Industry Department of Industrial Database and information about the factory production
Works
Thai Industrial Standards Oversees Thai Industrial Standards

Institute (TISI)
Office of Small and Medium Oversees database and information about SMEs.
Enterprise Promotion
Ministry of Interior Department of Lands Responsible for agriculture land management, including titling and registration
Ministry of Finance Customs Department The Customs Department controls imports and exports of goods
Combats illegal trade
Is responsible for collection of tariffs and duties.
Ministry of Foreign The Office of Agricultural Supports marketing of Thai agricultural products in the EU.
Affairs (MOFA) Affairs, Royal Thai Embassy Supports Royal Thai Embassy in representing Thai interests in EU policy and
Brussels decision making.
The stakeholder impact analysis, and the ways forward (section 4.2) should also consider the transformative
potential of the EUDR. Specifically to:
1. Meet the appropriate interests of the producer countries. This goes beyond the need for strong
commitments and actions on climate change but supporting relevant national ESG initiatives.
2. Prioritise the well-being of IPLCs, including smallholders, if their rights and interests are side-lined then in
turn they may be forced to rely on forests as a safety net, which may result in increased deforestation and
degradation.
3. Ensure it is implemented and enforced must synergise with relevant national, international (including
ASEAN) and global initiatives.
4.2. Potential cooperation approaches and support measures and activities
4.2.1. Approaches and support measures that can be facilitated or led by the EU agencies
The findings from this assessment clearly underline the value of the EU developing a program to ensure that the
EUDR delivers, not only on its explicit objectives as set out in the Regulation itself, but also that there are clear
benefits for countries like Thailand. This program would build on the goodwill that already exists from the
relationship developed through, for example, the VPA. Additionally, it would complement the support given to
CSOs in the country, such as to enhance their contribution to governance and development processes, with which
many of the needs regarding EUDR implementation and enforcement would align.
The interviewees often used a shotgun approach in proposing the types of interventions that would be included in
the program, this approach is both a reflection of their mixed understanding of the main components of the EUDR,
as well as the recognition of the work needed to have to meet the EUDR’s requirements including having a resilient
DDS in place. Some of the suggestions may also reflect some frustration among state and non-state actors
towards the EU about the EUDR, feeling that it goes against the country’s interests and poses significant threats
to the well-being of smallholders. The frustration, to a certain extent, also seems to be based on the feeling that
the EU should have been more proactive in consultation with producer countries in the development of the
Regulation.
Based on the aim of the EUDR, and the findings from the interviews, as well as the desk work, interventions should
be designed and implemented to have the following broad objectives:
1. Increase legal and deforestation-free trade flows

61
2. Reduce deforestation and forest degradation in Thailand

3. Strengthen forest governance, with emphasis on rights and participation of IPLCs
4. Increase the effectiveness of cooperation and policy/political dialogue between the EU and Thailand
5. Minimise risks and negative impacts resulting from EUDR’s implementation, especially on smallholders
and SMEs
6. Build on existing initiatives that could be integrated in Regulation more comprehensive approach
Based on these objectives the research team has proposed three overarching and interlinked programs comprised
of various activities. The programs are:
1. Awareness raising campaign (Table 20)

2. Capacity development program (Table 21)
3. Partnership development and collaboration (Table 22)
The EU and stakeholders in Thailand should work together on prioritising activities. Additionally developing the
EUDR communication strategy and plan, as well as a capacity development needs assessment (CDNA) would
help to refine the prioritisation, this includes identifying if certain regions of Thailand should be prioritised over
others. For example, the vast majority of the rubber and palm oil smallholders are found in the Southern Region,
58.9% and 84.0% respectively (Figures 6a and b) and therefore it may be that programs in that region will have a
larger outreach. However, one also needs to consider that these smallholders already have access to more
support than their peers in the north, for example, where deforestation and degradation are more of an issue, in
comparative terms (Annex 3).
4.2.1.1 Awareness raising

Table 20 Proposed activities as part of awareness raising campaign
Activity Alignment with broad Focal point Additional information

objective (1-6)
Specific objective
Development of 4-6 EUD, with support Consideration should be given to aligning with
national EUDR from DG ENV and DG national and international issues and initiatives
communication Communication gaps and INTPA, and EU raised in this report. For example, Thailand’s
strategy and plan tools identified and Delegations at imports of forest risk commodities from
strategy and plan in place ASEAN level as well neighbouring countries, and initiatives at ASEAN
to address these to as in AMS level. Failure to do so may lead to mixed
support implementation of messaging, but also inefficient use of resources
the EUDR. as well as missed opportunities for Thai suppliers
to get competitive advantage.
Consideration can be given to the questions

raised in awareness raising section (3.2.2).
The strategy and plan should align with the

development of the CDNA.
It must consider the various sensitivities shared in

this report, including possible formal opposition by
RTG.
National and sub- 4 - 6. EUD, with support The main findings of this assessment will be
national EUDR from DG ENV and DG shared in the national event. The findings of this
workshops Demonstrate EU’s INTPA assessment should be shared with RTG in
commitment to partnership
62
in implementation of the advance, as well as with relevant NSAs, including

EUDR. to enable their effective participation in the event.
EUD would share general strategy for program for

EUDR implementation in Thailand (including
Stakeholders understand objectives, actors, resources), also emphasising
possible support provided alignment with national initiatives (e.g., BCG,
by EU in EUDR National Strategy)
implementation
Appropriate consideration needs to be given to
ensure that stakeholders from outside of Bangkok
(i.e. in production and processing locales – e.g.
wood supply chain actors from the north, and
rubber and oil palm from the south) are able to join
the event.
Implementation of 4 - 6. EUD, with support These materials would be developed based on the
EUDR from DG ENV and DG national EUDR communication strategy and plan.
communication Raise awareness of the INTPA
strategy and plan main components of the The materials would be shared at appropriate
including EUDR to: EUDR milestones.
development and
1. Address The materials would be tailored for each
dissemination of
misunderstandings stakeholder, including guidelines to support their
appropriate
2. Create goodwill engagement with EUDR.
communication
among stakeholders
materials for key These materials can be hosted by the national
in Thailand towards
stakeholders to EUDR focal point and can include FAQ available
EUDR
raise awareness in Thai that is updated on a regular basis.
3. Increase
of the EUDR
understanding of the
main components of
the EUDR, and
implications for each
stakeholder group
Study tour for 4-6 EUD, with support The study tour would include field visits to better
relevant EU staff from DG ENV and DG understand the supply chains for different EUDR
EUD and colleagues in INTPA commodities, and the challenges and
Brussels from DG ENV opportunities for meeting requirements.
and DG INTPA have
improved understanding of Ideally this would be done before the national
the opportunities and EUDR workshop.
challenges facing EUDR
implementation, and the It would also be a symbolic gesture to RTG and
risks. NSAs that EU is keen to engage, including to
understand the challenges facing smallholders.
Public awareness 1 – 3, 5 & 6 EUD working with This can be aligned with EUD’s request for
campaign relevant RTG proposals on Enhancing CSOs' Contribution to
Increased public agencies Governance and Development Processes
awareness in Thailand to
support informed decision
making by consumers to
reduce domestic demand
for forest risk commodities.
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4.2.1.2 Capacity development

Table 21 Proposed activities as part of capacity development program

objective (1-6)
Specific objective
Capacity 1-6 EUD, with relevant Consideration should be given to include relevant
development NGO taking the lead national and international (including EU) initiatives
needs Understand the capacity in conducting the in the CDNA.
assessment gaps and needs for CDNA
(CDNA) different stakeholder Capacity development program should be drafted
groups, particularly based on the findings.
smallholders and SMEs in
Thailand to support EUDR The CDNA framework should be drafted by DG
implementation and ENV and DG INTPA to be used in other relevant
enforcement. producer countries, and then adopted for the Thai
context
Capacity 1-6 EUD, with relevant This can be funded by RTG with technical support
development RTG agency and provided by EU.
program for RTG RTG agencies have NGO taking the lead
agencies capacity to support supply in designing,
chain actors adhere to implementing the
EUDR requirements. capacity development
program, including
monitoring,
evaluation, and
learning (MEL)
Capacity 1-6 EUD, with relevant This can be co-funded by EU and RTG.
development NGO taking the lead
program for NGOs are better able to in designing, Important that NGOs that are included have
NGOs deliver capacity implementing the working relationship with farmer associations,
development program for capacity development RTG and SMEs, as well as larger companies
their constituents – program, including
particularly smallholders MEL
and SMEs, to support
EUDR implementation.
NGOs have capacity to

monitor implementation of
EUDR, including develop
and submit substantiated
concerns when
appropriate.
Capacity 1-6 EUD, with relevant Efforts should also be made to align the program
development NGO taking the lead with those of the buyer companies in each of the
program for Farmer associations have in designing, supply chains.
farmer capacity to support their implementing the
associations members’ compliance with capacity development This can be co-funded by EU and RTG.
EUDR. program, including
MEL
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4.2.1.3 Partnership development and collaboration

Table 22 Proposed activities to foster partnerships and collaboration

objective (1-6)
Specific objective
Clarify next steps 4-6 EUD, with guidance The first step can involve RTG suggesting if it
for the VPA from DG ENV and DG wishes to continue with the VPA, this will require
negotiations Relevant actors can INTPA as well as them understanding the likely workload and
determine the priorities RTG support for EUDR.
and allocation of
resources for VPA. The import controls for timber needs to be
addressed moving forward with the VPA may
Relevant actors can make facilitate this to be done in a timely manner.
the necessary actions,
including identifying This should be addressed before the workshop to
synergies between VPA ensure that this does not become a dominant
and EUDR. issue in the event.
Establish 1–6 EUD, DG ENV and This would also be linked with the development of
monitoring DG INTPA working the CDNA
system for Collect baseline data, data with relevant RTG
measuring the management system and agencies to develop
impact of the appropriate recourse the framework. The
EUDR and other mechanisms for EUDR Secretariat will
related addressing negative oversee the data
mechanisms impacts and to scale up collection and general
positive learnings to MEL.
ensure EUDR and related
mechanisms deliver,
including in an equitable
manner.
Synergise with 1 - 2, 4 – 6 DG ENV and DG ASEAN Single Window initiative may provide
other initiatives, INTPA synergies for documentation for trade within the
including Synergise EUDR with bloc, and for subsequent trade to the EU.
regulations in EU, relevant regulatory
EU MS and other initiatives addressing trade Engagement at the ASEAN level also needs to be
countries, in forest risk commodities, considered in context of importance of Thailand’s
including ASEAN addressing the likely trade with other AMS, as well as increase efforts
level complexities resulting from at regional level to address common challenges
different demands from and opportunities.
each.
4.2.1.4 Other proposals

• Consider allowing supply chains containing smallholders to be exempt for a set period of time from
having to provide geolocation information.
• Clarify that supply chains involving SMEs in Thailand will not need to meet the EUDR requirements
until the same time period as their equivalents in the EU.
• Consider waiving penalties for the first year of EUDR to allow companies and governments to set up
the systems to ensure compliance. An alternative suggestion is to return all funds attained from
penalties to support EUDR implementation and compliance in the producer country that was the source
of the commodity.
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• If, as expected, additional commodities will be included in the EUDR after the first review then it will be
of value to engage with the RTG as soon as possible so that preparations can be made. The
suggestion would be that the capacity development program (Table 21) would include representatives
from non-EUDR commodities, such as cassava, maize and sugar cane.
• Expand the focus of the Forest Partnerships to move beyond wood, and have clear plan for
engagement with Thailand.
• RTG can clearly benefit from being proactive in engagement with the EU in sharing existing DDS.
• Operators, such as Michelin and Bridgestone, should be encouraged to increase their efforts on
transparency in their supply chains. Reporting on which supply chains have complete traceability, and
which not and specific details of when and how to achieve this.
4.2.2. Suggested priority actions for RTG agencies
Table 23 provides an overview of the suggested priority interventions by RTG agencies. This includes establishing
a EUDR focal point (i.e., Secretariat). While the EUDR is quite different to the VPA in many ways, including the
fact that the VPA is effectively a trade agreement, having a national focal point would be highly beneficial,
especially for inter-agency coordination. Noting that the EUDR commodities are under two Ministries (MNRE and
MOAC), there are several options of where the focal point could be based:
• The Office of the Prime Minister, reflecting that it cuts across different ministries and departments
• MNRE, considering that it has overall responsibility in addressing deforestation and degradation
• MOAC reflecting the fact that they are the focal agency for six of the seven commodities.
Other activities would include the awareness raising campaign (Table 20) and the capacity development program
(Table 21).
An additional activity is that RTG further develops the plan for the implementation of the National Strategy
(especially 4.5.5 regarding traceability in supply chains), This would be valuable, ensuring that the initiative aligns
with EUDR, and other legislation being developed to address trade in forest risk commodities such as the UK’s
Environment Act, as well as relevant national initiatives including the BCG Model, review of CF Act, as well as
other initiatives that may indirectly impact on smallholders e.g. plan to expand number and area of National Parks.
It is suggested that emphasis is also placed on creating a national portal supporting traceability and transparency
for the supply chains for all commodities, this would build on various initiatives, including the Single Window. The
first step should be understanding of the plan for the National Strategy, and an analysis of the systems that are
already in place such as the e-Form, Single Window etc.
An additional suggestion is that a EUDR data management program is initiated. While the RTG has clearly
invested in collecting data in the agriculture and forestry sectors, there are still gaps. Investment in improved data
collection and management, including having a focal agency with a clear mandate to oversee this would allow,
among other things, understanding of the impact of the EUDR on SMEs and smallholders. This would be in line
with efforts by RTG to improve traceability in supply chains, as well as the Single Window, e-Farm systems, One
Map Initiative and so on. As with the EUDR focal point, there are several options for the lead agency on this
including the Office of the Prime Minister considering that the data cuts across different ministries and
departments. Consideration needs to be given to data management and security.
Table 23. Suggested priority actions for RTG agencies
Responsible Action
agency
EUDR focal - Establish a EUDR one-stop service to advise private sector, including SMEs, and
point in RFD, smallholders
MOAC or Office
of the Prime - Work with EUD and other EU agencies on developing EUDR communication strategy and
Minister plan
66
- Work with EUD and other EU agencies on conducting CDNA and coordinate the
implementation of subsequent capacity development program.
- Coordinate the data collection and management for assessing the impacts of the EUDR
Office of Small - Facilitate the further development of the database of SMEs for each key commodity
and Medium
Enterprise - Work with EUDR focal point on awareness raising and capacity development program for
Promotion SMEs
Department of - Support data management to better understand the awareness raising and capacity needs
Industrial Works of relevant industry stakeholders
(DIW)
- Support the implementation of awareness raising and capacity development programs
DIT - Support data management to better understand the awareness raising and capacity
needs of relevant industry stakeholders
- Support the implementation of awareness raising and capacity development programs
Thai Industrial - Coordinate the revision of the relevant standards to support compliance with EUDR and
Standards other relevant initiatives
Institute (TISI)
DTN - Work with EUDR focal point and other government agencies to monitor the impacts of the
EUDR
- Prepare data for sharing in relevant meetings including for FTA negotiations.
Customs - Work with EUDR focal point to implement awareness raising and capacity development
Department program support exporters to have documents in place for EUDR compliance
The Department - Liaise with EU agencies and relevant Thai state and non-state actors.
of European
Affairs
The Royal Thai

Embassy
Brussels
(including also
The Offices of
Agricultural and
Commercial
Affairs)
Table 24 again provides an overview of suggested actions for RTG agencies for each of the EUDR commodities.
Table 24. Suggested priority actions for RTG agencies for each commodity
Commodity Focal Suggested action

agency
Wood RFD - Coordinate development of national deforestation and forest degradation dataset
DNP - Collect and share data on deforestation and forest degradation area within
protected areas
DMCR - Collect and share data on deforestation and forest degradation area within coastal
areas
TEFSO - Work with EUD and other EU agencies to identify ways forward for FLEGT VPA.
- Analyse the TLAS process and adjust according to the EUDR
67
Palm oil DIT - Help the local farmers who plant palm oil inside the forest to ensure understanding
and compliance with EUDR
- Work with TSPOA and RSPO to adjust to ensure compliance with EUDR.
- Work with relevant companies to support them to adjust their chain of custody to
ensure it meets EUDR and also upcoming national traceability requirements
Rubber RAOT - Help the local farmers who plant rubber inside the forest to ensure understanding
and compliance with EUDR
- Work with PEFC and FSC to adjust to ensure compliance with EUDR.
Cattle DLD - Collect and share data on stakeholders in cattle supply chains.
- Analyse the Cattle Industry Traceability System and support adjustment to the
EUDR.
Coffee MOAC - Collect and share data on stakeholders in coffee supply chains.
- Work with companies, including SMEs, to analyse their traceability systems and
support adjustment to EUDR
Cocoa MOAC - Collect and share data on stakeholders in cocoa supply chains.
Soya MOAC - Collect and share data on stakeholders in soya supply chains.
68
ANNEXES
Annex 1. Forest area in Thailand during the period 1973-2020
Table A1. Forest area in Thailand during the period 1973-2020
Year Forest area (ha) Forest area as % of country area Data source
1973 22,170,700 43.21 RFD
1976 19,841,700 38.67 RFD
1978 17,522,400 34.15 RFD
1982 15,660,000 30.52 RFD
1985 15,086,600 29.04 RFD
1988 14,380,300 28.03 RFD
1989 14,341,700 27.95 RFD
1991 13,669,800 26.64 RFD
1993 13,355,400 26.03 RFD
1995 13,148,500 25.62 RFD
1998 12,972,200 25.28 RFD
2000 17,011,078 33.15 RFD
2004 16,759,098 32.66 RFD
2005 16,100,130 31.38 RFD
2006 15,865,259 30.92 RFD
2008 17,158,565 33.44 Mahidol University
2013 16,339,126 31.57 Kasetsart University

69
Annex 2. Enforcement actions by DMCR and DNP in recent years
Table A2. Enforcement actions by DMCR in land that it administers (2018-2022)114
Detail 2018 2019 2020 2021 2022 Total
Total cases
Number of cases 224 177 118 118 42 679
Number of arrests 48 33 58 24 56 219
Land encroachment cases
Number of cases 218 173 116 108 41 656
Area (rai) 9,013.2 5,219.8 2,822.4 2,680.7 2,553.5 22,289.5
Area (ha) 1,442.1 835.2 451.6 428.9 408.6 3,566.3
Illegal logging cases
Number of cases 6 4 2 10 1 23
Wood seized (m3) 10.07 6.18 3.94 2.88 1.47 24.54
Table A3. Enforcement actions by DNP in land that it administers (2017-2021)115
Detail Unit 2017 2018 2019 2020 2021
Number of cases Case 4,249 3,369 2,596 2,519 1,839
Arrests Person 2,030 2,037 1,527 1,336 1,176
Confiscated materials
Teak
- Logs Cum. 149.64 57.45 47.54 141.76 65.49
- Sawn Cum. 119.56 30.15 12.89 12.71 18.34
Non-teak
- Logs Cum. 1,232.59 684.23 885.92 1,001.65 1,877.24
- Sawn Cum. 350.45 1,396.54 193.92 147.23 315.50
Illegal construction Unit 769 181 432 75 31
Products from restricted wood Piece 2 23 0 0 0
Restricted minor forest products Item 5 6 8 10 8
114
Mangrove and Coastal Resources Protection Subdivision, Protection and Suppression Division, Department of Marine and Coastal Resources
115
Department of National Park Wildlife and Plant Conservation ,
https://www.dnp.go.th/statistics/2564/doc/%E0%B8%95%E0%B8%B2%E0%B8%A3%E0%B8%B2%E0%B8%87%2011%20%E0%B8%97%E0%B
8%B3%E0%B8%9C%E0%B8%B4%E0%B8%94%E0%B8%81%E0%B8%8F%E0%B8%AB%E0%B8%A1%E0%B8%B2%E0%B8%A2%20%E0%B
8%9B%E0%B8%B5%202560%20-%202564.xls
70
Live wildlife Unit 4,852 7,318 11,052 1,792 2,256
Wildlife carcasses Unit 1,039 1,521 2,423 1,104 1,066
Forest land cleared ha 5,697.25 3,494.30 2,643.96 3,958.82 842.95

71
Annex 3. Forest loss and reforestation in Thailand for period 2018-2020 and
2021-2022
Table A4. Location of deforestation and reforestation in regions of Thailand for period year 2018 – 2020 and
2021 - 2022116
Region Area (ha)

2018 - 2020 2021 - 2022
Deforestation % Reforestation % Deforestation % Reforestation %
Northern 66,803.37 46.59 34,593.06 28.40 23,506.96 47.87 10,540.87 28.59
Northeastern 22,709.77 15.84 17,581.96 14.43 10,172.92 20.72 9,103.81 24.69
Central 8,691.53 6.06 19,883.32 16.32 4,288.70 8.73 9,549.02 25.90
Eastern 8,245.32 5.75 8,146.99 6.69 2,565.59 5.23 969.83 2.63
Western 20,193.15 14.08 22,507.65 18.48 6,127.37 12.48 3,314.35 8.99
Southern 16,738.03 11.67 19,097.42 15.68 2,440.24 4.97 3,390.41 9.20
Total 143,381.17 100.00 121,810.38 100.00 49,101.78 100.00 36,868.28 100.00
Note that the data is collected during the period January to March or April
116
Data from Forest Land Management Office, Royal Forest Department
72
Annex 4. State forests and responsible government agencies
Thailand’s forests fall under distinct categories which determines how they are used, and which government
agency is responsible for their management.
Table A5. Categorisation and management of Thailand’s forests in 2019117
Types Managing agency Area Forest area Non-forest area

(million ha) (million ha) (million ha)
Protected area DNP 10.92 9.21 1.71
NRF RFD 9.72 5.45 4.27
Permanent Forest 1.55 0.39 1.16
- Transferred to RFD RFD 0.54 0.16 0.38
- Non-classified land use Land Development
Department (LDD) 1.01 0.22 0.78
Mangrove forest DMCR 0.39 0.20 -
Production Forest FIO 0.15 0.15 -
Green area
administrated by other
government agencies 11.37 0.75 -
- Self-help settlement Department of
Social Development
and Welfare
(DSDW) 0.85 0.08 -
- Land settlement Cooperative
cooperative Promotion
Department (CPD) 0.45 0.02 -
- State property The Treasury
Department (TD) 1.40 0.32 -
Agricultural land reform Agricultural Land
Reform Office
(ALRO) 8.05 0.21 -
Public land Department of
Lands (DOL) 0.62 0.13 -
Remaining forest area -
outside public lands 17.66 0.24 -
117
73
Annex 5. Additional data on agricultural production in Thailand
Based on the data from Farmer Analytic System of Thailand (https://aiu.doae.go.th/bi_report/) in 2021 Thailand
7,363,226 households had farming as a significant source of income. Of these 6,707,455 households (91.09%)
have agriculture as their main occupation. In 2021 there were 17,776,262 people living in the 7,363,226
households (average of 2.41 individuals per/household) (Table A6). Most of the farmers were more than 46 years
old (6,048,579 individuals or 82.15 percent of all farmers) (Table A7).
Table A6. Number of farming households and household members in Thailand (2017 – 2021)118
2017 2018 2019 2020 2021
Number of households 7,010,191 7,271,759 7,554,562 7,384,180 7,363,226
Household members (person) 18,168,700 18,899,284 18,749,641 17,922,467 17,776,262
Table A7. Age grouping of farmers in Thailand (2021)119
Age (years) Number of households Percentage
18 – 25 34,978 0.48
26 – 35 319,510 4.34
36 – 45 960,159 13.04
46 – 55 2,045,533 27.78
56 – 65 2,154,883 29.27
More than 65 1,848,163 25.10
Total 7,363,226 100.00
Most farmers have legal ownership of their land (Table A7). The average holding is 2.33 hectares per household.
Around 40.52% of the farmers land holding is less than 1.6ha (10 rai) totalling 2,341,706 hectares. Only 5.99% or
380,096 households have cultivated area of more than 7.2ha (45 rai) (Table A9).
Table A8. Type of land rights of Thai farmers (2021)120
Land right type Number of households Area (hectare)
Own land 4,693,085 10,651,153
Tenant farmers 1,145,076 3,017,484
Other (public land, free use) 1,772,198 4,053,255
Total* 6,341,040 17,721,892

* Farmers can have land rights in more than one category
Table A9. Number of farmer households grouped by size of cultivated area (2021)121
Size of cultivated area Number of households Cultivated area (hectare)
118 Farmer map 2564 by Department of Agriculture Extension, https://aiu.doae.go.th/Farmermap/farmermapbook64-202204-watermark.pdf
119
Farmer map 2564 by Department of Agriculture Extension, https://aiu.doae.go.th/Farmermap/farmermapbook64-202204-watermark.pdf
120
121
74
Less than 5 rai (<0.8 ha) 1,161,310 569,079
5 – 10 rai (0.8 - 1.6 ha) 1,407,983 1,772,627
10.01 – 15 rai (1.6016 - 2.4 ha) 1,116,393 2,271,478
15.01 – 20 rai (2.4016 - 3.2 ha) 846,983 2,415,026
20.01 – 25 rai (3.2016 - 4 ha) 543,028 1,964,246
25.01 – 30 rai (4.0016 - 4.8 ha) 353,712 1,571,046
30.01 – 35 rai (4.8016 - 5.6 ha) 230,523 1,204,226
35.01 – 40 rai (5.6016 - 6.4 ha) 178,671 1,080,915
40.01 – 45 rai (6.4016 - 7.2 ha) 122,341 835,593
More than 45 rai (>7.2 ha) 380,096 4,037,657
Total 6,341,040 17,721,892
Based on the 30,323 farming households that filed data, the average income from the Thai agriculture sector in
2021 was US$2,842.07/household/year (Table A10). More than 54% of total households had annual income from
farming at less than US$1,781.40 (<60,000THB) (Table A11). The farmers also often have a debt problem - on
average having US$1,882.89 debt linked to agriculture, and US$1,399.00 of debt for non-agricultural related
expenditure (Table A12).
Table A10. Source of farmer income (2021)122
Source of income Average (US$/person/year)
Income from agriculture sector 2,842.07
Income outside agriculture sector 1,168.00
Average income from and outside agriculture sector 4,010.07
Table A11. Farmer income group by income range (2021)123
Range of income Income from agriculture sector
Number of household members Percentage
< 60,000 Baht (<US$1781) 16,378 54.01
60,000 – 119,999 Baht (US$1781-3562) 7,621 25.13
120,000 – 179,999 Baht (US$3563-5344) 2,273 7.50
180,000 – 499,999 Baht (US$5345-14,845) 3,441 11.35
500,000 – 999,999 Baht (US$14,846-29,691) 449 1.48
> 1,000,000 Baht (>US$29,691) 161 0.53
Total 30,323 100.00
122
123
75
Table A12. Source of farmers‘ debt (2021)124
Source of debt Average
Debt linked to agriculture 63,418 Baht/person/year (US$1883/person/year)
Debt from expenditure outside of agriculture 47,120 Baht/person/year (US$1399/person/year)
Average income from and outside agriculture sector 110,539 Baht/person/year (US$3282/person/year)
124
76
Annex 6. Thailand’s imports and exports of EUDR relevant commodities 2019-

2021125
Table A13a. Value (US$) of Thailand’s imports of cattle from other key AMS, total for ASEAN and world (2019-
2022)
Imports Cambodia Indonesia Lao PDR Malaysia Myanmar Philippines Viet Nam ASEAN total World total
2019 850,933 1,817,521 166,289 1,467,410 40,070,619 26,080 15,172,755 66,132,509 577,062,196
2020 195,647 1,528,152 182,346 758,881 26,360,688 907 13,446,406 43,788,504 524,125,368
2021 519,651 1,734,823 13,224 2,099,742 435,498 23,586 14,467,254 19,855,894 666,009,140
2022 1,261,923 3,480,179 1,441 1,257,014 72,317,683 19 16,767,829 23,979,777 846,914,976
Table A13b. Value (US$) of Thailand’s exports of cattle to other key AMS, total for ASEAN and world (2019-
2022)
Exports Cambodia Indonesia Lao PDR Malaysia Myanmar Philippines Viet Nam ASEAN total World total
2019 23,842,582 56,763,077 181,316,539 9,264,859 4,703,237 2,032,974 242,612,031 519,075,145 654,619,223
2020 22,316,558 51,080,527 128,949,802 10,145,505 12,447,168 1,142,270 226,473,707 459,164,504 509,274,334
2021 13,830,118 61,362,068 61,548,918 9,287,253 4,346,289 1,213,995 222,998,562 404,541,644 504,220,719
2022 15,957,780 86,838,401 47,906,221 11,475,327 5,133,566 1,059,458 287,630,453 359,485,959 647,559,095
Table A13c. Value (US$) of Thailand’s imports of cocoa from other key AMS, total for ASEAN and world (2019-
2022)
Imports Cambodia Indonesia Lao PDR Malaysia Myanmar Philippines Singapore Viet Nam ASEAN total World total
2019 - 11,984,615 - 62,166,394 - 1,012,138 2,859,579 420,938 89,683,015 199,728,733
2020 - 12,435,528 - 62,495,727 8 1,507,024 2,734,539 487,671 90,817,085 187,379,080

2021 - 20,436,347 - 72,069,050 - 1,594,832 4,870,560 237,210 112,138,316 211,395,417
2022 - 28,791,013 - 86,812,994 - 2,104,227 3,783,290 383,727 133,937,326 259,570,925
Table A13d. Value (US$) of Thailand’s exports of cocoa to other key AMS, total for ASEAN and world (2019-2022)
Exports Cambodia Indonesia Lao PDR Malaysia Myanmar Philippines Singapore Viet Nam ASEAN total World total
2019 2,018,168 451,565 1,618,988 2,152,105 6,766,073 663,659 20,695 923,411 15,033,641 73,633,085
2020 1,855,384 523,017 2,447,833 847,281 6,139,848 282,620 56,067 99,166 12,392,461 37,849,750
2021 1,380,077 1,559,999 2,187,449 2,076,013 6,569,329 445,399 26,345 195,485 14,729,505 42,217,511
2022 2,755,675 2,403,469 2,824,748 5,277,643 9,895,000 1,225,568 81,492 777,575 25,843,560 69,380,038
125
Data analysis uses HS Codes from Annex 1 of EUDR. The trade data was downloaded from ASEAN Stats Data Portal.
https://data.aseanstats.org/trade-annually.
77
Table A13e. Value (US$) of Thailand’s imports of coffee from other key AMS, total for ASEAN and world (2019-
2022)
2019 - 7,764,865 10,526,515 13,762,643 - - 21,683 66,148,332 98,261,388 107,027,757

2020 - 5,154,076 8,128,909 17,592,225 58 26 156,131 86,151,574 117,183,527 126,970,233
2021 - 8,329,804 17,738,663 5,222,098 16 228 61,403 85,785,874 117,138,175 128,331,539
2022 - 1,799,976 26,951,033 8,137,573 75,562 8 47,841 123,135,862 160,148,084 175,139,601
Table A13f. Value (US$) of Thailand’s exports of coffee to other key AMS, total for ASEAN and world (2019-2022)
2019 798,282 - 8,863 94,375 36,170 5,191 27,650 17,772 988,304 4,041,055
2020 650,694 122 13,091 65,907 19,009 11,783 31,621 13,837 806,203 3,020,946
2021 484,650 5,344 28,545 25,971 21,864 32,640 50,157 76,209 730,489 3,774,056
2022 733,225 - 19,201 40,970 36,420 24,439 445,153 73,226 1,376,853 3,846,311
Table A13g. Value (US$) of Thailand’s imports of oil palm from other key AMS, total for ASEAN and world (2019-
2022)
2019 - 74,646,622 - 55,567,781 1,149,228 416,871 1,319,441 - 133,404,746 175,473,340
2020 - 117,110,099 - 68,441,097 1,485,302 1,270,468 2,253,294 - 190,638,648 218,506,262
2021 - 155,144,630 122,100 117,465,213 1,189,676 718,111 6,322,533 18,187 281,082,186 336,569,285
2022 149,325 197,127,541 - 166,265,006 1,083,436 715,760 2,782,170 440,276 368,696,920 426,794,138
Table A13h. Value (US$) of Thailand’s exports of oil palm to other key AMS, total for ASEAN and world (2019-
2022)
2019 7,025,089 405,527 2,754,308 64,206,115 31,144,307 796,729 313,030 2,600,903 109,246,007 274,576,527
2020 5,847,551 522,262 3,742,772 46,773,847 33,305,669 849,779 462,789 1,655,828 93,160,498 276,268,565
2021 5,798,916 526,156 6,441,569 218,823,255 48,916,821 872,396 429,753 2,619,546 284,428,993 1,054,574,996
2022 10,482,324 2,552,246 8,210,900 212,239,382 132,241,152 1,969,618 12,629,740 3,312,285 383,637,647 1,736,311,616
Table A13i. Value (US$) of Thailand’s imports of rubber from other key AMS, total for ASEAN and world (2019-
2022)
2019 1,474,973 52,966,122 279,148 114,939,142 30,575 11,679,739 21,413,426 33,766,111 287,540,217 1,341,530,794
2020 874,400 46,249,107 108,784 108,925,721 66,806 9,686,105 16,058,849 33,314,435 254,453,410 1,234,456,457
2021 1,006,228 43,686,457 25,400 134,457,133 83,282 11,913,965 12,958,704 46,199,942 312,228,628 1,510,083,003
2022 534,564 48,431,398 3,535 100,432,595 127,377 11,908,388 12,178,069 45,904,298 277,199,631 1,433,394,772
78
Table A13j. Value (US$) of Thailand’s exports of rubber to other key AMS, total for ASEAN and world (2019-2022)
2019 130,917,032 183,621,440 44,114,578 871,712,412 90,256,930 129,319,847 50,327,653 321,911,970 1,823,426,098 12,589,645,726
2020 106,290,557 141,464,124 43,572,911 920,629,077 88,023,513 106,956,076 48,217,162 306,071,785 1,762,490,632 12,637,519,331
2021 95,645,941 252,122,878 41,655,444 1,104,789,745 77,570,220 152,121,464 67,816,422 351,224,383 2,144,361,794 17,071,162,768
2022 90,074,312 235,847,681 41,936,213 987,797,445 82,903,462 167,591,890 64,839,750 392,312,680 2,064,727,611 15,306,972,426
Table A13k. Value (US$) of Thailand’s imports of soya from other key AMS, total for ASEAN and world (2019-
2022)
2019 9,064,044 - - 18,547 99,900 - 51 - 9,182,542 2,489,656,223

2020 2,995,163 - - 2,459,951 1,008,070 - 293,249 - 6,756,440 2,610,201,694
2021 4,443,510 1,608 - 2,818 276,847 1,290 - 112,831 4,838,903 3,631,063,000
2022 2,651,796 1 - 13,782 3 - - 156,469 2,822,050 3,621,141,614
Table A13l. Value (US$) of Thailand’s exports of soya to other key AMS, total for ASEAN and world (2019-2022)
2019 21,789,550 9,303,769 14,029,215 2,489,003 6,391,610 25,496,408 1,089,846 22,021,158 102,610,559 104,900,290
2020 26,439,594 9,573,040 12,787,533 5,006,987 9,222,267 22,712,232 226,474 29,557,033 115,525,158 125,537,610
2021 37,101,338 22,976,153 19,628,913 14,088,262 28,720,536 35,575,111 880,307 69,551,765 228,522,384 260,680,807
2022 56,587,825 27,078,505 22,003,601 22,857,797 32,162,305 44,715,443 755,520 70,393,150 276,554,146 304,726,275
Table A13m. Value (US$) of Thailand’s imports of wood from other key AMS, total for ASEAN and world (2019-
2022)
2019 17,373,351 206,629,999 24,257,987 256,048,283 31,739,418 10,592,499 203,063,452 96,172,141 853,340,435 3,742,126,254
2020 13,727,216 158,857,674 13,431,185 183,490,823 20,705,262 3,959,773 196,618,145 116,693,297 712,425,144 3,405,134,103
2021 15,122,189 199,004,141 11,476,496 179,285,102 20,125,395 9,497,365 201,550,253 129,637,889 776,348,257 4,573,547,032
2022 20,780,613 236,009,034 16,273,290 204,899,358 24,193,878 16,874,365 166,420,979 192,996,074 892,177,987 4,667,377,907
Table A13n. Value (US$) of Thailand’s exports of wood to other key AMS, total for ASEAN and world (2019-2022)
2019 94,078,416 189,655,826 84,763,196 233,343,514 71,431,634 71,352,496 39,215,498 378,601,801 1,163,996,744 4,981,409,672
2020 82,451,046 162,540,253 90,918,589 259,806,676 53,069,657 50,395,880 32,563,521 401,050,767 1,134,213,294 4,893,177,364
2021 92,071,680 238,592,826 123,716,200 297,282,030 39,709,640 68,851,684 43,943,387 434,412,684 1,339,383,610 6,375,463,786
2022 95,426,965 239,593,227 139,553,375 268,148,974 63,523,423 59,371,474 54,273,017 387,132,981 1,308,100,541 6,346,218,806
79
80
Annex 7. Overview of production of EUDR relevant commodities in Thailand
7.1 Cattle
Early estimates for the year 2022 are that Thailand was home to 1.424 million cows of production.126 During the
period 2017 - 2021, domestic beef consumption has been relatively steady, with an increase of only 0.06 percent
per year. In 2022, the beef consumption is estimated to be 1.491 million cows or equivalent to 250,500,000 tons
of beef, which is 62.81% higher than the year 2020 due to a result of the measures to control the spread of the
Coronavirus Disease 2019 (COVID-19).
Table A14. Thailand cattle production and consumption (2018 – 2022)127
Detail 2018 2019 2020 2021 2022

(estimate)
Production (million cows) 1.223 1.199 1.231 0.780 1.424
Weight (1,000 tons) 205.464 201.432 206.811 131.100 239.229
Consumption (million cows) 1.261 1.262 1.342 0.961 1.491
Weight (1,000 tons) 211.848 212.020 225.439 153.859 250.500
During the period 2018 - 2022, the volume and value of live cattle exports decreased by 13.11% and 8.99% a
year, respectively. Most of the exports are to neighbouring countries including Viet Nam, Lao PDR, with some then
exported to China. During the period 2018 - 2022, the quantity and value of exports of cattle products decreased
at a rate of 7.49 percent and 13.69 percent per year, respectively. During 2018 - 2022, the quantity and value of
imported live cattle decreased by 24.29% and 8.50% a year, respectively. Almost all of the live cattle imported to
Thailand end up being exported (Table A15).
Table A15. Exports and imports of live cattle and cattle products (2018 – 2022)128
Detail 2018 2019 2020 2021 2022* Change in %

Export - Living cows
Quantity (million cows) 0.252 0.319 0.304 0.198 0.159 -13.11
Value (million US$) 124.57 193.22 178.39 104.54 93.19 -8.99
Cattle products
Weight (million tons) 0.096 0.084 0.322 0.091 0.063 -7.49
Value (million US$) 1.37 0.99 1.09 0.56 0.76 -13.69
Import- Living cows
Quantity (million cows) 0.137 0.086 0.063 0.004 0.156 -24.29

Value (million US$) 62.48 44.00 37.73 11.01 70.60 -8.50
Cattle products
Weight (million tons) 13.067 13.676 18.950 22.850 25.500 20.33
Value (million US$) 83.55 94.94 111.27 139.45 197.68 26.61
126
Office of Agricultural Economics , The Customs Department, https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
127
Office of Agricultural Economics, The Customs Department. https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
128
Office of Agricultural Economics , https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
81
* Estimate
The Department of Livestock Development (DLD) are the responsible government agency for cattle production in
the country. The DLD e-Regist system129 is used to collect the data from the farmers. The DLD has the Cattle
Industry Traceability System130 the System is managed by the Bureau of Livestock and Standards and
Certification, DLD. The system is capable of monitoring, tracking and providing traceability in the production chain
starting from the breeding process, quality monitoring before production, standard production process, process of
collecting and delivering products to overseas buyers and consumers. The work of the traceability system must
be fast, transparent, and responsive to the needs of all stakeholders involved starting from farmers to
manufacturers, intermediary buyer, and exporter until the consumer. By monitoring various processes, action can
be taken immediately, when consumers, producers, buyers, intermediaries, or the exporter encounters a problem
or has doubts in the food production process, can be traced back in the production process.
An overview of the Thai cattle supply chain is presented in Figure A1, while Table A16 shares information on cattle
type and ownership for the period 2018 – 2022, showing a significant growth in the number of cattle and cattle
owning smallholders in the country.
Table A16. Overview of cattle type and numbers (2018 – 2022)131
Detail 2018 2019 2020 2021 2022

Native cattle
Amount 3,082,133 3,338,181 3,502,996 4,166,472 4,900,711
Number of Farmers 531,444 561,255 575,164 692,637 807,685
Purebred cattle
Amount 106,407 123,884 141,887
Number of Farmers 18,837 22,590 26,903
2,203,465 2,368,862
Crossbreed cattle
356,930 374,722
Amount 2,423,068 3,021,441 4,056,274
Number of Farmers 362,593 458,901 615,419
Beef cattle
Amount 159,753 164,764 197,669 270,609 295,239
Number of Farmers 13,634 14,763 17,821 23,296 24,657
Total
Amount 5,445,351 5,871,807 6,230,140 7,582,406 9,394,111
Number of Farmers 828,477 871,508 909,324 1,142,614 1,413,395
Figure A1. Cattle supply chain132
129
http://eregist.dld.go.th/
130
http://trace2.dld.go.th/dldcattle/
131
Information and Statistic Group, Information and Communication Technology Center, Department of Livestock Development
132
Office of Agricultural Economics
82
Table A17. Number of cattle traders and export values to EU classified by HS code during 2018 – 2022133
HS code 2018 2019 2020 2021 2022
Trader Value Trader Value Trade Value Trade Value Trade Value
(US$) (US$) r (US$) r (US$) r (US$)
ex 0102 * 817 0 0 0 0 0 0 0 0
ex 0201 0 0 0 0 0 0 0 0 0 0
ex 0202 * 2 0 0 0 0 0 0 0 0
ex 020610 0 0 0 0 0 0 0 0 0 0
ex 020622 0 0 0 0 0 0 0 0 0 0
ex 020629 0 0 0 0 0 0 0 0 0 0
160250 0 0 0 0 * 63 0 0 0 0
ex 4101 * 276,207 * 115,397 * 152,807 * 112,080 * 150,891
ex 4104 13 8,421,729 15 1,020,613 4 777,183 5 626,088 4 407,072
ex 4107 39 7,270,617 36 5,642,098 30 4,329,089 33 6,596,460 31 4,146,46

5
Total 15,969,372 6,778,108 5,259,142 7,334,628 4,704,428
* No data
133
Ministry of Commerce. https://ietrade.moc.go.th/ , https://tradereport.moc.go.th/
83
7.2 Cocoa
There is limited information on cocoa production in Thailand, reflecting that it is not viewed as a nationally
economically important crop. Records show that the first cacao trees were planted in Thailand in 1903134. Much
of the country is suitable for the production of cocoa. Cocoa was initially planted in the South and spread to other
regions across the country. Its main production areas are in Nakhon Si Thammarat, Chumphon, Surat Thani. The
Department of Agriculture has promoted the planting of cocoa trees to replace coconut plantations in the south
and west since 1995135.
According to data from the Agricultural Production Information System, Department of Agricultural Extension136,
in 2018 the production of cocoa was 75,860 kilograms with a value of just over US$100,000, there has been
significant increase in production since then – in 2022 production was over 1.2 million kilograms, with a value just
under $US 1 million (Table A18).
Table A18. Cocoa production in Thailand (2018 – 2022)137
Year Amount (kilogram) Price (US$/kilogram) Value (US$)
2018 75,860 1.35 102,534.44
2019 125,720 1.05 132,167.22
2020 859,249 0.48 414,868.79
2021 882,135 1.00 882,622.82
2022 1,260,590 0.77 969,362.45
During the period 2015 – 2019, the export of cocoa beans has increased from 138 kilograms in 2015 to 925 tons
in 2019. Almost all the exports of cocoa beans go to India (99% of the total), with small amounts being exported
to Lao PDR and Japan. The export of cocoa products in the same period has, however, decreased from 32,862
tons in 2015 down to 19,063 tons in 2019. In 2019, Thailand 80% exports of cocoa products to were to Japan
followed by Myanmar (5%) and Malaysia (4%). The exports to the EU have declined in recent years (Table A20).
Table A19. Cocoa plantations in Thailand (2018 – 2022)138
Details 2018 2019 2020 2021 2022
Number of farmer households 157 311 1393 2,365 2,859
Cultivated area (ha) 105.76 277.28 960.48 1,601.28 2,007.52
Productive area (ha) 5.76 14.72 64.32 87.84 292.96
Production (ton) 76 126 859 882 991
134
https://www.doa.go.th/hc/chumphon/wp-content/uploads/2020/02/Cacao-in-Thailand.pdf
135
https://www.bot.or.th/Thai/MonetaryPolicy/RegionalEconomy/DocLib14/RL%20cocoa.pdf
https://kb.mju.ac.th/assets/img/articleFile/256501253c7c0f413011432ab65b83c8e2330fc8.pdf
https://www.doa.go.th/hort/wp-
content/uploads/2020/12/%E0%B8%AA%E0%B8%96%E0%B8%B2%E0%B8%99%E0%B8%81%E0%B8%B2%E0%B8%A3%E0%B8%93%E0%B
9%8C%E0%B8%81%E0%B8%B2%E0%B8%A3%E0%B8%9C%E0%B8%A5%E0%B8%B4%E0%B8%95%E0%B9%82%E0%B8%81%E0%B9%8
2%E0%B8%81%E0%B9%89_%E0%B8%9E%E0%B8%A4%E0%B8%A8%E0%B8%88%E0%B8%B4%E0%B8%81%E0%B8%B2%E0%B8%A2%
E0%B8%9963.pdf
136
https://production.doae.go.th/
137
Department of Agricultural Extension
138
Department of Agricultural Extension, https://production.doae.go.th/
84
Table A20. Number of cocoa traders and export values to EU classified by HS code (2018 – 2022)139
HS code 2018 2019 2020 2021 2022
Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value
(US$)
18010000 * 1,489 0 0 0 0 * 3 0 0
18020000 0 0 0 0 0 0 0 0 0 0
1803 * 71,083 0 0 0 0 0 0 0 0
18040000 * 503 0 0 0 0 0 0 0 0
18050000 * 151 * 1 * 183 * 186 * 13
1806 18 5,454,127 22 6,536,322 19 2,740,382 24 1,375,921 20 3,685,393
Total 5,527,353 6,536,323 2,740,565 1,376,110 3,685,406
* No data
Finally, the Trade Policy and Strategy Office (TPSO), Department of Foreign Trade, is exploring the use of
blockchain technology (known as TraceThai.com system) for chain of custody for organic products, including
cocoa.
7.3 Coffee
In Thailand Robusta coffee is mainly grown in the southern provinces, with Arabica coffee grown in the northern
provinces. This is significant considering that generally Robusta coffee plants require more sun compared to the
more shade tolerant arabica. This will have various implications including on clearance of forests and trees.
During the past 5 years, the coffee production area has decreased. Production also fell during the period from
24,687 tons in 2017/18 to 18,689 tons in 2021/22. The average coffee yield per rai fluctuated during the period
from 91 kilograms in 2017/18 to 107 kilograms in 2018/19 and then fell back to 92 kilograms in 2021/22 (Table
A21). The overall changes in production were mainly because farmers cut down old coffee trees and replaced with
new plants, as well as with other plants such as durian.
Table A21. Coffee production in Thailand (2018 – 2023)140
Year Farmer household Productive area Product (ton) Productivity

(rai) (kilogram/rai)
2017/18 27,425 270,605 24,687 91
2018/19 28,848 247,133 26,414 107
2019/20 29,761 224,624 22,481 100
2020/21 30,969 228,705 21,775 95
2021/22 28,535 202,812 18,689 92
2022/23* N/A 210,614 19,908 95
* Estimate
139
140
Office of Agricultural Economics ,
https://www.oae.go.th/view/1/%E0%B8%95%E0%B8%B2%E0%B8%A3%E0%B8%B2%E0%B8%87%E0%B9%81%E0%B8%AA%E0%B8%94%E
0%B8%87%E0%B8%A3%E0%B8%B2%E0%B8%A2%E0%B8%A5%E0%B8%B0%E0%B9%80%E0%B8%AD%E0%B8%B5%E0%B8%A2%E0%
B8%94%E0%B8%81%E0%B8%B2%E0%B9%81%E0%B8%9F/TH-TH
85
Domestic demand for coffee has increased, resulting in reduction in exports - exports of beans fell from 699 tons
in 2018 to 609 tons in 2022, a 12.9% decrease. The exports of instant coffee fell from 10,270 tons to 7,487 tons
during the same period (Table A22).
Table A22. Volume and value of coffee beans and instant coffee exports from Thailand (2018 – 2023)141
Year Coffee bean Instant coffee*

Amount (ton) Value (million US$) Amount (ton) Value (million US$)
2018 699 4.16 10,270 20.10
2019 602 4.10 7,441 18.99
2020 467 3.07 9,301 25.79
2021 606 3.44 7,450 21.76
2022* 609 3.33 7,487 20.81
2023* 612 3.42 7,524 21.11
* Estimate
141
Office of Agricultural Economics , https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
86
Figures A2 and A3 provide an overview of the supply chains for Arabica and Robusta coffee in Thailand.
Figure A2. Arabica coffee supply chain142
Figure A3 Robusta coffee supply chain143
Table A23. Export amount and value of coffee and relevant products (2016-2020)144
Product 2016 2017 2018 2019 2020
Tonne mil. Tonne mil. US$ Tonne mil. US$ Tonne mil. US$ Tonne mil.
US$ US$
Green coffee 188 1.59 305 1.78 469 2.90 385 2.70 290.58 1.91
beans
Ground 187 1.59 187 1.21 166 1.40 160 1.32 130.42 1.11
coffee
Instant coffee 34,190 117.10 30,927 113.52 28,473 99.86 24,812 92.34 25,823.42 99.62
142
143
144
Thailand Trading Report System, Office of The Permanent Secretary for Ministry of Commerce
87
Table A24. Number of coffee traders and export values to EU classified by HS code (2018 – 2022)145
HS code 2018 2019 2020 2021 2022
Trader Value Trader Value Trader Value Trader Value Trader Value
(US$) (US$) (US$) (US$) (US$)
0901 22 304,427 24 302,380 21 321,046 32 355,608 15 355,509
7.4 Palm oil
Thailand is the third largest palm oil producer in the world146, but has only 3.9% of the world’s market share147.
The Government aims to expand the palm oil area under cultivation to 10 million rai (1.6 million ha) by 2029, as of
2020 the area of oil palm plantation covered 995,490 ha.
Little of the palm oil produced in Thailand is certified - 2.8% of palm oil produced in the country is RSPO certified148.
According to most recent publicly available data from May 2022, RSPO in Thailand has 63 members, of which 19
are RSPO certified smallholder groups, representing over 5400 farmers with a certified area of 27,295 ha. An
additional 34 groups, representing 1386 smallholders and 4442 ha are in the process of achieving RSPO
certification149. In October 2022 RSPO and Thailand Environment Institute (TEI) launched Thailand Sustainable
Palm Oil Alliance (TSPOA) to promote sustainable palm oil production in Thailand.
The palm oil sector in Thailand is under the supervision of the National Palm Oil Policy Committee. The Committee
is chaired by one of the Deputy Prime Ministers demonstrating its national importance.
During 2018 – 2022 the area of production, production and production per area has been increasing 3.50%, 3.84%
and 0.30% a year, respectively (Table A25).
Table A25. Overview of Thai palm oil production and consumption (2018-2022)150
2018 2019 2020 2021 2022
Households growing oil palm 338,131 364,864 394,214 400,575 N/A
Productive area (million ha) 0.85 0.91 0.94 0.97 0.99
Production (million ton) 15.48 16.42 16.22 16.79 17.39
Productivity (ton/ha) 18.12 18.10 17.27 17.26 17.53
Domestic consumption (million ton) 1.23 1.36 1.03 1.24 1.26
Renewable energy – bio-diesel (million ton) 1.20 1.53 1.50 1.14 1.12
In 2021 Thai palm oil exports (HS code 1511.10, 1511.90, 1513.21 and 1513.29) were 779,483.67 tons, with a
value of US$929.98 million. The export volume and value have grown in recent years reflecting the high palm oil
price on the global market, as well as Thailand’s increased production. The main export markets for palm oil are
India (65.74% of the total Thai palm oil export), Malaysia (22.22%), Myanmar (5.15%), Kenya (4.43%) and China
(1.25%) (Table A26).
Table A26. Top 5 export markets for Thailand’s palm oil products (2018 – 2022)151
145
146
https://rspo.org/press-release-enhancing-thai-palm-oil-production-to-meet-global-sustainability-demands/
147
TEI. 2022. The report on guidance for development of Thailand Sustainable Palm Oil Alliance (TSPOA). TEI/ RSPO. Not available online.
148
TEI. 2022. The report on guidance for development of Thailand Sustainable Palm Oil Alliance (TSPOA). TEI/ RSPO. Not available online.
149
https://rspo.org/press-release-enhancing-thai-palm-oil-production-to-meet-global-sustainability-demands/
150
Department of Trade Negotiations, https://www.dtn.go.th/th/content/category/detail/id/72/cid/984/iid/2616
151
Department of Trade Negotiations, https://www.dtn.go.th/th/content/category/detail/id/72/cid/984/iid/2616
88
Rank Export 2018 2019 2020 2021

market
Quantity Value Quantity Value Quantity Value Quantity Value
(ton) (million (ton) (million (ton) (million (ton) (million
US$) US$) US$) US$)
1 India 269,452.20 167.29 185,893.57 88.77 163,962.80 106.03 534,123.04 611.36
2 Malaysia 116,070.07 104.02 102,580.39 59.26 65.375.28 43.56 159,737.59 206.61
3 Myanmar 34,647.31 29.61 37,595,55 30.72 32,294.52 32.80 33,371.87 47.92
4 Kenya 17,003.93 10.52 26,252,59 13.31 12,716.00 7.80 35,491.17 41.19
5 China 9,970.16 9.16 5,529.75 4.21 3,276.79 3.27 8,944.34 11.66
World 462,045.97 332.01 370,641,51 205.97 285,873.55 202.21 779,483.67 929.98
Figure A4 provides an overview of the palm oil supply chain in Thailand.
Figure A4. Supply chain of Thailand’s palm oil production in 2021152
152
Industry Outlook 2022-2024: Palm Oil Industry, https://www.krungsri.com/en/research/industry/industry-outlook/agriculture/palm-oil/io/oil-palm-
industry-2022-2024
89
90
According to analysis by Krungsi, the Thai financial institution, there are roughly 390,000 households that grow oil
palm across the country (RTG data estimates that there are nearly 365,000 palm oil smallholders in the country).
Most of these growers are smallholders. The few large growers tend to have their own mills for extracting crude
palm oil.
Currently there are 131 mills producing crude palm oil in Thailand153. The Office of Industrial Economics (OIE)
estimates that the country’s installed processing capacity comes to around 5.6 million tonnes of crude palm oil per
year. These mills also produce a wide range of by-products including kernel meal that is used as for animal feed
and the palm shells, fibre and other waste that may be used to produce energy or electricity and organic fertilizer.
The next stage of the supply chain are palm oil refineries, of which there are 21 in the country, with an annual
production capacity of 2.5 million tonnes. Large operators are often connected through their investments to other
parts of the palm supply chain including, for example, crude palm oil mills and the production of vegetable oils.
Other industries are linked to the supply chain including those that utilise palm oil these include biodiesel (B100)
refineries, food processors, the chemicals industry, and oleochemicals production.154
Based on the data from Palm Oil Data Center of the Department of Internal Trade, Ministry of Commerce there
are 6 different actors in the palm oil supply chain after the farmers sell their products 1) collection centre 2) palm
oil mill 3) refinery plant 4) depository warehouse 5) biodiesel Plants and 6) oleo-chemical industry. In addition,
intermediaries also play a significant role, though data is not available on their actual numbers.
Table A27. Actors in Thai palm oil supply chain155
Detail Number
Collection centre 2,227
Palm oil mill 149
Refinery plant 22
Depository warehouse 13
Biodiesel Plants 16
Oleo-chemical industry 2
Table A28. Number of palm oil traders and export values to EU classified by HS code (2018 – 2022)156
HS code 2018 2019 2020 2021 2022
Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value Trader Value (US$)
(US$)
1511 * 255 4 1,401 * 51 * 403 4 18,991,511
120710 * 35,887 * 133,463 * 233,632 5 38,989 * 23,040
151321 * 98 * 6,108 * 2,931 0 0 0 0
151329 0 0 0 0 0 0 0 0 0 0
230660 * 1,980 0 0 0 0 0 0 0 0
382319 * 3,072,931 4 1,912,758 * 288,632 * 262,712 * 321,598
153
Department of Internal Trade
154
https://www.krungsri.com/en/research/industry/industry-outlook/agriculture/palm-oil/io/oil-palm-industry-2022-2024
155
https://palm.dit.go.th
156
91
291590 0 0 * 34 * 38 * 3,615 0 0
382370 * 3,154,138 6 2,378,426 * 2,310,577 8 1,484,383 7 2,688,517
382311 0 0 * 165 0 0 0 0 0 0
290545 * 1,177,716 * 12,410 * 254,083 * 177 * 284,351
291570 * 2,388 * 5 0 0 0 0 0 0
382312 0 0 * 12,633 0 0 0 0 0 0
Total 7,445,393 4,457,403 3,089,944 1,790,279 22,309,017
* No data
7.5 Soya
During the period 2019 - 2023, the cultivated area of soya has decreased by 12.68%. In 2022/23, the estimated
planted area of soya stood at 13,452.80ha (Table A29), production has also fallen significantly during the period.
One of the main reasons for the reduction in area planted with soya is the high labour costs involved in its
cultivation, especially during the harvest period, coupled with the lower return compared to other crops, for
example, rice and maize.
Table A29. Soya production (2019 – 2023)157
Year Smallholder Cultivated area (ha) Production (ton) Productivity

(tons/ha)
2019 19,056 24,209.92 41,165 1.70
2020 15,588 16,670.88 26,283 1.58
2021 N/A 13,761.76 22,800 1.66
2022* N/A 13,916.32 23,173 1.67
2023* N/A 13,452.80 22,799 1.69
2024** N/A 12,990.40 22,252 1.71
* Estimate
** Target
Most soya demand in Thailand is met by imports (Table A30). Because of the invasion of Ukraine and the
subsequent upheaval to various commodity markets, there has been a great deal of uncertainty in soya trade, with
prices increasing markedly. One result is that the government have started to promote domestic soya production.
Table A30. Thai soya trade (tons) (2018 – 2023)158
Year Production Imports*** Total supply Domestic consumption Exports***
Soya Oil Breed Processing
2018 41,165 2,722,969 2,764,134 1,908,771 2,724 849,456 3,183
2019 26,283 3,209,277 3,235,560 2,158,112 1,855 1,072,394 3,199
157
158
Office of Agricultural Economics. https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
92
2020 22,800 4,044,716 4,067,516 2,788,838 2,332 1,274,628 1,718
2021 23,173 3,996,772 4,019,945 2,836,627 1,566 1,180,810 942
2022* 22,799 3,400,000 3,422,799 2,653,550 1,513 766,686 1,050
2023* 22,252 3,500,000 3,522,252 2,641,698 1,461 878,193 900

* Estimate
** Target
*** Data from Customs Department
In 2020,15,588 farmers planted soya in Thailand. An overview of the soya supply chain is shared in figure A5.
Figure A5. Soya supply chain159
Table A30. Number of soya traders and export values to EU classified by HS code (2018 – 2022)160
HS code 2018 2019 2020 2021 2022
Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value
(US$)
1201 * 402 * 873 * 4,545 * 3,789 0 0
120810 0 0 0 0 0 0 0 0 0 505
1507 5 27,509 4 13,530 * 1,378 * 606 * 1,747
2304 0 0 * 150 0 0 0 0 * 49
Total 27,911 14,553 5,923 4,395 2,301
* No data
159
160
https://ietrade.moc.go.th/ , https://tradereport.moc.go.th/
93
7.6 Rubber
During the period 2018 to 2022 the area of planted rubber in Thailand grew from 3.20 million hectares to 3.51
million hectares. The production of rubber has slightly increased during the same period from 4.74 million tons to
4.76 million tons. However, the production per area is down from 1,500 kilogram per hectare (raw rubber) in 2018
to 1,375 kilogram per hectare in 2022.
The number of households growing rubber has fallen in recent years from 1,731,469 households in 2018 to
1,682,638 in 2021, however, the rubber harvested area for these households has increased (Table A31). Figure
A6 provides an overview of the main actors in the rubber supply chain in Thailand.
Table A31. Number of household and harvested area of rubber plantation (2018 to 2021)161
Region 2018 2019 2020 2021
HH Harv. area HH Harv. area HH Harv. area HH Harv. area
Northern 107,889 174,284.16 106,825 197,315.8 106,530 211,383.68 106,419 211,559.68
North-eastern 472,635 829,114.24 476,168 897,169.76 474,803 935,718.72 473,378 936,527.20
Central 123,493 365,419.52 119,863 371,848.64 118,056 370,891.84 115,136 361,398.56
Southern 1,027,452 1,957,791.36 1,011,708 1,972,022.88 1,001,213 1,999,517.12 987,705 2,006,605.28
Total 1,731,469 3,326,609.28 1,714,564 3,438,357.12 1,700,602 3,517,511.36 1,682,638 3,516,090.72
HH = Household, Harv. area = Harvested area (ha).
Figure A6 provides an overview of the rubber supply chain in Thailand.
Figure A6 (next page). Thai Rubber Supply Chain 2021162
161
162
https://www.krungsri.com/en/research/industry/industry-outlook/agriculture/rubber/io/rubber-2022
94
95
Based on the Rubber Intelligence Unit163, of the Office of Industrial Economics, there are 1,319
companies/cooperatives involved in the rubber supply chain (Table A32). However, it is not possible to identify
how many of these are SMEs.
Table A32. Actors in Thai rubber supply chain164
Detail Number of company / cooperative
Upstream natural rubber production 373
Rubber product manufacturer 533
Rubber wood product manufacturer 315
Dealer 40
Service provider 8
Recycling operator 4
Other 46
Total 1,319
Rubber products are Thailand’s third largest export good/product in terms of value, after Vehicles and parts, and
Computers and parts. The export market for rubber has faced some challenges in recent years, including
increased trade costs, such as for shipping containers. The main exports markets for Thai rubber products are:
• China, which imported 2.30 million tons in 2022, compared to 2.68 million tons in 2018.
• Malaysia imported 0.40 million tons in 2022, compared to 2.68 million tons in 2018
• Japan imported 0.19 million tons of rubber in 2022, down from 0.21 million tons rubber in 2018
Table A33 provides an overview of the number of traders involved in the rubber trade to the EU.
Table A33. Number of rubber traders and export value to EU classified by HS code (2018 – 2022)165
HS 2018 2019 2020 2021 2022

code
Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value (US$)
4001 71 438,393,290 62 488,520,088 63 351,043,951 66 652,816,118 59 677,649,470
4005 14 48,985,186 13 41,362,362 10 44,182,320 16 72,992,635 9 61,209,438
4006 8 212,444 4 166,942 4 85,090 5 85,874 5 56,245
4007 5 16,674,161 7 15,486,385 6 18,028,460 6 19,301,622 6 19,555,083
4008 24 3,468,034 21 4,664,452 30 4,101,271 29 4,557,249 34 3,855,786
4010 54 5,116,734 49 4,585,714 45 3,257,467 49 5,516,429 36 3,752,544
4011 59 422,229,487 52 485,095,194 56 396,926,094 58 585,225,711 54 731,135,481
4012 26 4,144,925 29 15,968,479 26 2,337,241 22 3,864,257 25 3,238,733
163
http://rubber.oie.go.th/
164
Rubber Intelligence Unit, Office of Industrial Economics
165
96
4013 24 13,379,761 19 12,478,342 19 12,499,087 23 18,562,346 22 14,183,854
4015 49 260,263,923 53 249,595,774 135 597,523,550 87 650,017,019 58 317,812,668
4017 25 3,395,244 23 2,917,334 18 3,074,093 18 4,671,476 18 1,049,871
Total 1,216,263,189 1,320,841,066 1,433,058,624 2,017,610,736 1,833,499,173
RAOT’s Rubber Strategic Plan (2017-2036)166 has ambitious plans for the further development of rubber sector in
Thailand.
1. Rubber cultivated area: Reduce the rubber cultivated area from 3.73 million hectares in 2016 to
2.94 million hectares in 2036
2. Rubber products: Increase the rubber products from 35.84 kilograms/hectare/years in 2016 to
57.6 kilograms/hectare/years in 2036.
3. Proportion of domestic consumption: Increase the proportion of domestic consumption from
13.6% in 2016 to 35.0 in 2036.
4. Export value of rubber products: Increase the export value of rubber products from US$7352.94
million in 2016 to US$23,529.41 million in 2036.
5. Income from rubber plantation: Increase the income from rubber plantation from 352.47
baht/rai/year in 2016 to 582.35 baht/rai/year in 2036.
RAOT is also actively supporting certification of rubber in the country – as of 2022 there is approximately 16,000ha
of FSC rubber plantations in the country. RAOT aims to ensure that at least half of rubber plantations in Thailand
meet FSC standards in 2026167.
7.7. Wood
Eucalyptus, rubber wood and teak are the main wood species produced in the country (Table A34).
Table A34 Production of timber in Thailand (2021)168
Details Production Unit

Log production from land that is not plantations
• Teak 2,610 m3
• Other species 6,834 m3

Log production from plantations
• Teak 63,912 m3
• Eucalyptus 88,124 ton
• Other species 14,272 ton
• Rubber 36,496 m3
Wood processing
• Teak wood processing from land other than plantations 4,534 ft3
• Other species from land other than plantations 16,728 ft3
• Teak wood processing from plantation 134,471 ft3
166
https://www.rubber-tyre.com.vn/en/news/thailand-raot-plans-to-develop-the-rubber-industry-for-20-years-2-92.html
167
https://www.nationthailand.com/thailand/economy/40022811. Rubber Strategic Plan 20 Years (2017 - 2036)
168
Forest statistics in 2021. Information provided by FIO, https://forestinfo.forest.go.th/Content.aspx?id=10408
97
• Teak wood interlocking from plantation 48,105 ft3
• Teak wood products from plantations 1,093 ft3
The timber sector is an important export for Thailand - in 2021 Thailand exported US$3.7 billion of wood products
and imported US$0.98 billion. Much of the imported timber is processed and then exported (Table A35). China
(US$937,794,099), Viet Nam (US$12,245,687), Malaysia (US$8,315,028) and India (US$1,776,782) are the
largest wood export markets for Thailand.
Table A35. Thailand’s imports and exports of wood Products (2021)169
Item Import Export Unit
Amount US$ Amount US$
Fuelwood 130,159 124,046 403 380 Kg.
Wood in chips or particles 72,072,750 1,715,478 2,688,239,927 211,064,641 Kg.
Wood charcoal 61,420,087 8,046,337 22,396,670 9,007,426 Kg.

Logs 220,050 3,945,588 63,373 9,510,269 Cum.
Sawnwood 504,278 92,426,166 2,445,616 955,365,123 Cum.
Veneer sheets 10,078,087 22,977,204 185,581,037 9,257,331 Cum.
Particle board 11,195,743 5,778,051 2,055,493,050 453,297,288 Kg.
Fiberboard 18,055,714 11,830,250 2,671,587,994 775,656,135 Kg.
Plywood 1,478,658 118,259,206 310,930 3,535,445 Cum.
Flooring panels 498,058 3,576,486 172,862 7,309,197 Kg.
Wood furniture 5,400,288 166,979,609 22,871,821 559,639,278 Unit
Other wood products 54,652,140 66,336,420 66,255,802 149,225,383 Kg.
Wood pulp 577,137,301 426,066,558 169,627,992 118,776,871 Kg.
Other fiber pulp 65,696,408 55,264,203 1,192,525,492 439,127,591 Kg.
Total 983,325,601 3,700,772,358
TIS 2861 1-2017 (Forest Products Supply Chain Management) covers the requirements for forest products supply
chain management. This requirement describes the various procedures concerning the source of the wood raw
material. This standard includes an operational guideline relating to supply chain management which a supplier
may choose to implement either through physical sorting or percentage method.
Through the work on the VPA the RTG and partners have developed the TLAS which consists of five
components170:
1. Legality verification
2. Supply chain control (SCC)
3. Verification of compliance
4. FLEGT licensing
169
Forest statistics in 2021, https://forestinfo.forest.go.th/Content.aspx?id=10408
170
https://tefso.org/en/tlas-system/
98
5. Independent audit
The SCC determines the processes for wood control and data management through the critical control points
(CCPs) along the wood supply chain to ensure the compliance with wood supply chain in terms of quantity and
quality in each CCPs by government agencies and private companies. Figure A7 provides an overview of the
supply chain control for wood.
Figure A7. Main components of draft supply chain control for wood171
Figure A8 explains the components of teak product industry supply chain. In general wood from plantations will be
pass through a log landing and then onto processing plant e.g., a sawmill. Four main types of wood products
(sawn woods, interlocking woods, unqualified logs, sawdust, and wood residues) are processed for specific
purposes.
Figure A8. Components of Teak Product Industry Supply Chain: Teak Wood Users172
171
TEFSO. https://tefso.org/en/supply-chain-control-2/.
172
P. Diloksumpun, S. Arunwarakorn / Kasetsart Journal of Social Sciences 42 (2021) 703–714
99
In 2019 there were 14,149 sawmills in Thailand. The 32.7% of the sawmills are in the Central Region (Table A36).
Table A36. Sawmills and Wood Products Factories in 2019173
Bangkok Central Northern North- Eastern Southern Total Mills

eastern
Sawmills 22 202 73 216 90 490 1,093
Manual sawmill 0 8 10 510 285 380 1,193
Wood working by 772 1,672 626 1 2 0 3,073

machinery
Wood working by human- 5 116 197 323 17 45 703
power
Sawn timber shop 439 1,051 476 517 162 408 3,053
Wood products shop 732 1,555 1,398 701 216 283 4,885
Wood processing for 0 14 53 6 1 2 76

commercial purposes
Total 1,970 4,624 2,898 2,275 774 1,608 14,149
Data from the Department of Industrial Works (2022) and from the National Statistical Office (2020) are used to
understand the actors in the wood supply chains. There are a total of 8,058 establishments with 246,257 workers
in the supply chain, again it is not known how many are SMEs (Table A37).
173
Royal Forest Department, data from 2019 https://forestinfo.forest.go.th/Content.aspx?id=10384
100
Table A37. Number of establishments and workers in wood processing sector in Thailand categorised according
to HS code
ID Business Types Number of Number of workers Average

Establishments number of
Male Female Total
Workers
15203* Wooden shoe production 3 22 2 24 8
16101* Sawing wood 1356 44,816 21,075 65,891 49
16102* Wood baking and treatment 49 1,036 1,044 2,080 42
16210* Manufacture of veneers and similar 147 8,096 3,930 12,026 82

boards
16220* Production of wood used in 890 12,882 6,398 19,280 22
construction and assembly of
buildings
16230* Production of wooden containers 461 11,347 9,862 21,209 46
16291* Manufacture of home appliances 40 1,953 2,402 4,355 109

made of wood and cork
16299* Manufacture of home appliances 591 6,835 1,207 8,042 14
made of wood and cork
(Uncategorized in other types)
17011* Pulp production 114 3,946 3,725 7,671 67
31001* Wood furniture production 1411 49,393 37,672 87,065 62
92001** Wholesale of wood in the rough and 2,996 12,999 5,615 18,614 6
products of primary processing of
wood
Total 8,058 153,325 92,932 246,257 31
* Data from Department of Industrial Works in 2022
** Data from National Statistical Office in 2020
Analysis by FIO of its members found that 5,644 stakeholders are involved in its supply chains (Table A38), those
include actors that are directly, such as customers, and indirectly involved, such as mass media that communicate
issues related to FIO’s work, in FIO’s work.
Table A38. Stakeholders in FIO’s supply chain and business174
Stakeholder In person
Business partners 65
Co-investors 5
Commercial competitors 9
Contractors 1,348
Creditors 158
174
Data from Forest Industry Organization. https://www.fio.co.th/fioWebdoc65/p650221-7.pdf
101
Customers 1,592
Debtors 72
External agencies 109
Government organizations 525

Mass media 14
Local communities 393
Superintendent 38
Worker 1,316
Total 5,644
Table A39. Number of wood traders and export values to EU classified by HS code (2018 – 2022)175
HS code 2018 2019 2020 2021 2022
Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value (US$) Trader Value (US$)
4401 17 982,414 10 881,257 6 805,217 6 429,329 10 3,755,048
4402 21 468,086 18 530,67 10 366,574 8 49,654 13 298,989
4403 * 8,593 * 1,961 0 0 0 0 0 0
4404 * 12,927 * 5,852 0 0 * 642 0 0
4405 0 0 0 0 * 279 * 186 * 299
4406 0 0 0 0 0 0 0 0 0 0
4407 * 2,122 * 4,436 * 27,500 0 0 * 6,270
4408 10 133,159 9 493,685 * 31,765 * 2,426 4 189,685
4409 7 2,184,956 9 942,965 6 774,604 7 773,840 7 2,382,996
4410 13 251,908 13 1,627,054 10 1,504,207 9 1,629,046 11 1,492,593
4411 14 3,751,407 12 3,427,287 8 2,928,018 8 3,773,939 8 4,485,935
4412 7 1,545,159 5 2,039,490 6 2,379,522 * 2,161,885 5 2,217,860
44130000 * 16 * 19 * 1 * 183 0 0
4414 109 1,006,482 92 697,568 59 774,675 44 747,235 54 414,196
4415 102 4,495,168 99 6,404,604 80 3,004,146 71 3,447,650 84 4,561,592
44160000 ** ** ** ** ** ** ** ** ** **
4417 * 4,556 5 4,401 4 2,525 * 1,039 4 741
4418 31 363,988 28 416,057 18 615,891 17 1,011,814 20 818,794
ex 4419 133 11,687,850 129 9,822,446 108 7,975,881 95 12,132,924 106 17,149,567
4420 181 7,987,662 150 7,438,986 124 2,879,235 96 3,917,229 118 5,503,751
175
102
4421 171 3,091,585 171 2,927,166 130 2,481,613 101 3,266,750 130 2,757,274
940330 28 70,882 23 106,018 11 19,136 5 3,617 9 18,355
940340 35 968,984 25 667,834 12 661,730 10 1,006,354 15 352,599
940350 50 427,995 41 268,295 33 298,399 15 342,375 29 526,29
940360 224 15,992,944 211 16,225,03 168 14,533,907 152 14,842,381 143 9,343,913
94039030 ** ** ** ** ** ** ** ** ** **
94061000 ** ** ** ** ** ** ** ** ** **
4900 ** ** ** ** ** ** ** ** ** **
Total 55,438,843 38,177,381 42,064,825 49,540,498 55,750,457
* No data.
** HS code not in the system
103
Annex 8. Production of cassava, maize and sugar cane in Thailand
8.1 Cassava
Table A40. Cultivated area, production and productivity of cassava in Thailand (2018 – 2023) 176
Year Productivity area Production Productivity (ton/hectare)

(million hectares) (million tons)
2018 1.332 29.368 22.043
2019 1.387 31.080 22.413
2020 1.427 28.999 20.323
2021 1.665 35.094 21.078
2022 1.588 34.007 21.421
2023* 1.618 34.749 21.475

* Forecast
Table A41. Number and location of Cassava farmers (2018 – 2021)177
Region 2018 2019 2020 2021
Northern 103,557 N/A 115,002 160,833
Northeastern 339,347 N/A 390,675 501,488
Central 80,685 N/A 82,077 97,907
Total 523,589 N/A 587,754 760,228
Table A42. Amount and value of imported cassava and products (2018 – 2022)178
Year Fresh cassava Chip, pellets Starch Total products
Raw Modified
Amount Value Amount Value Amount Value Amount Value Amount Value
(million (million (million (million (million (million (million (million (million (million
tons) US$) tons) US$) tons) US$) tons) US$) tons) US$)
2018 0.59 37.950 1.53 226.607 0.002 0.941 0.016 23.377 2.138 288.875
2019 0.90 58.717 1.25 215.715 0.001 0.430 0.016 24.975 2.167 299.837
2020 0.72 42.775 2.29 389.494 0.005 2.671 0.011 18.898 3.026 453.838
2021 0.44 30.907 2.41 368.215 0.004 1.811 0.014 20.070 2.868 421.004
2022* 0.93 66.195 3.05 457.262 0.008 3.784 0.013 22.027 4.001 549.381
176 Office of Agricultural Economics, https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf

177 Office of Agricultural Economics
178
Office of Agricultural Economics, https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
104
* Estimate
8.2 Maize
Table A43. Cultivated area, production and productivity of maize in Thailand (2018/19 - 2022/23)179
Year Cultivated area Production Productivity

(million hectares) (million tons) (ton/hectare)
2018/2019 1.109 5.07 4.572
2019/2020 1.123 4.54 4.043
2020/2021 1.134 5.00 4.409
2021/2022 1.098 4.94 4.499
2022/2023 1.090 4.95 4.541
Table A44. Number and location of maize farmers in Thailand (2018 – 2021)180
Region 2017/2018 2018/2019 2019/2020 2020/2021
Northern 324,002 335,178 335,197 344,530
Northeastern 77,378 92,768 89,029 77,904
Central 30,604 32,879 35,410 41,423
Total 431,984 460,825 459,636 463,857
Table A45. Domestic use, exports and imports of maize in Thailand (2017 – 2022)181
Year Domestic Exports*** Imports***

consumption**
Amount Value Amount Value
(million ton)
(million tons) (million US$) (million tons) (million US$)
2017 8.08 0.32 71.34 0.10 17.80
2018 8.24 0.08 20.81 0.15 27.35
2019 8.51 0.002 0.59 0.68 157.86
2020 8.34 0.001 0.21 1.59 286.53
2021 8.57 0.026 7.62 1.83 377.74
2022* 7.98 0.001 - 1.50 -

* Estimate
** Data from Thai Feed Mill Association
*** Data from Customs Department
179
180
181
105
8.3 Sugar cane

Table A46. Cultivated area, production and productivity of sugar cane in Thailand (2018/19 - 2022/23)182
Year Cultivated area Production Productivity Sugar Production

(million hectares) (million tons) (kilogram/hectare) (million tons)
2017/18 1.790 131.72 73.57 14.71
2018/19 1.914 128.53 67.17 14.58
2019/20 1.714 75.97 44.33 8.29
2020/21 1.485 66.95 45.09 7.59
2021/22* 1.525 92.05 60.37 10.16

2022/23* 1.618 105.86 65.44 11.94
* Estimate
Table A47. Number and location of sugar cane farmers (2018 – 2021)183
Region 2017 2018 2019 2020 2021
Northern 55,303 56,976 49,340 48,727 33,127

Northeastern 202,788 190,865 184,781 144,292 104,432
Central 45,273 41,047 42,936 43,708 24,336
Southern 21 14 16 22 10
Total 303,385 288,902 277,073 236,749 161,905
Table A48. Domestic use, exports and imports of sugar cane in Thailand (2017 – 2023)184
Year Domestic Exports*** Imports***

consumption**
Amount (million Value (million US$) Amount (million tons) Value (million US$)
(million tons)
tons)
2018 2.51 9.25 2,965.93 0.0002 0.39
2019 2.48 9.95 3,180.94 0.0003 0.51
2020 2.31 5.51 1,842.92 0.08 35.45
2021 2.29 3.57 1,439.94 0.09 35.72
2022* 2.50 6.40 3,004.74 0.13 55.75
2023* 2.60 12.00 - 0.14 -
* Estimate
** Office of the Cane and Sugar Board
*** Customs Department
182
Office of the Cane and Sugar Board, and Office of Agricultural Economics,
https://www.oae.go.th/assets/portals/1/files/jounal/2565/231225652566.pdf
183
Office of Agricultural Economics, http://farmerone.oae.go.th:9502/analytics/
184
106
Annex 9. Standards and certification schemes used in Thailand that are

recognised by RTG
Table A49. Standards and certification schemes used and recognised by RTG
Commodity Abbreviation Name

Cattle GMP-GAP Good Manufacturing Practice-Good Agricultural Practice
HACCP Hazard Analysis Critical Control Point
Halal Halal Food
JMGA Japan Meat Grading Association
PA SU SAD OK Department of Livestock Development
TACFS 6001-
Beef
2004
TAS 6402(G)-
Good Agricultural Practices for Dairy Cattle Farm
2562
TAS 9019-2007 Good Manufacturing Practices for Cattle and Buffalo Abattoir
TIS 1009-2533 Beef Ball, Pork Ball and Chicken Ball
USDA U.S. Department of Agriculture

Cocoa Code of Practice for the Prevention and Reduction of Ochratoxin A Contamination
TAS 9064-2022
in Cocoa Beans
TIS 137-2550 Cocoa Powders For Industrial Use
GMP Good Manufacturing Practices

Coffee EU organic European Union Organic
Fair Trade Fair Trade USA
FSSC 22000 Food Safety System
GHPs Good Hygiene Practices
GMP Codex FAO/WHO
Halal Halal Food
ISO 22000 Requirements for a Food Safety Management System
PGS Participatory Guarantee Systems
SCA Specialty Coffee Association
TIS 522-2561 Roasted coffee
TIS 573-2561 Instant coffee
TIS 585-2528 Green coffee
TAS 5701-2018 Arabica Green Coffee
TAS 5700-2018 Robusta Green Coffee
TAS 5903-2010 Good Agricultural Practices for Coffee

107
IFOAM The Global Organic Mark
The Rainforest
Alliance Certified
TIS 1169-2561 Coffee mix
USDA U.S. Department of Agriculture
UTZ Certified UTZ Certified

Palm oil RSPO Roundtable on Sustainable Palm Oil
TAS 9037-2023 Good Practices for Oil Palm Bunch Collection Center
TAS 5904-2021 Good Agricultural Practices for Oil Palm

TAS 5909(G)-
Principles for Sustainable Production of Oil Palm and Palm Oil
2020
TAS 5909-2020 Principles for Sustainable Production of Oil Palm and Palm Oil
TAS 5702-2019 Oil Palm Bunch
TAS 9037-2012 Good Manufacturing Practices for Oil Palm Bunch Collection Center
TIS 288-2561 Edible Refined Palm Oil
TIS 2888-2561 Palm Oil Ash for Use as admixture In Concrete

Rubber FSC Forest Stewardship Council
TAS 5707-2022 Thin Brown Crepe Rubber– Premium Grade
TAS 5706-2022 Ribbed Smoked Sheets – Premium Grade
TAS 5911-2021 Good Manufacturing Practices for Field Latex Collecting Center
TAS 5910-2020 Good Agricultural Practices for Para Rubber Part 2: Cup Lump Production
TAS 5908-2019 Good Agricultural Practices for Para Rubber Part 1: Field Latex Production
TAS 5907-2018 Good Manufacturing Practices for Crepe Rubber
TAS 5906-2013 Good Manufacturing Practices for Ribbed Smoked Sheet
TIS 173-2529 Latex foam rubbers
TIS 521-2527 Rubber-based adhesive
TIS 538-2548 Single-use sterile surgical rubber gloves
TIS 625-2559 Natural rubber latex male condoms - Requirements and test methods
TIS 969-2533 Rubber nipples for baby bottles
TIS 980-2552 Natural rubber latex concentrate
TIS 1025-2539 Baby dummies
Single-use medical examination gloves - P.1: Specification for gloves made from
TIS 1056-2556
rubber latex or rubber solution
TIS 1425-2540 Latex foam rubber mattresses
Flexible cellular polymeric materials - Sponge and expanded cellular rubber

TIS 1895-2542
products -Specification - P.1: Sheeting
108
Rubber condoms – Guidance on the use of 4074 in quality management of natural

TIS 2352-2550
latex rubber condoms
TIS 2353-2550 Rubber condoms for clinical trials measurement of physical properties
TIS 2476-2552 Household rubber gloves
TIS 2505-2553 Rubber gloves for food industry
TIS 2556-2554 Rubber threads – Specification
TIS 2577-2556 Rubber threads - Methods of test
Rubber - Determination of magnesium content of field and concentrated natural

TIS 2627-2558
rubber latices by titration (cyanide-free method)
TIS 2632-2558 Latex, Rubber-Determination of Total Solids Content
TIS 2633-2558 Natural rubber latex concentrate - Determination of alkalinity
TIS 2634-2558 Rubber, natural latex concentrate - Determination of KOH number
TIS 2640-2558 Rubber latex, natural, concentrate - Determination of volatile fatty acid number
TIS 2643-2558 Rubber, raw natural, and rubber latex, natural - Determination of nitrogen content
TIS 2644-2558 Natural rubber latex concentrate - Determination of boric acid content
TIS 173-2529 Latex foam rubbers
TIS 521-2527 Rubber-based adhesive
TIS 538-2548 Single-use sterile surgical rubber gloves
TIS 625-2559 Natural rubber latex male condoms - Requirements and test methods
TIS 969-2533 Rubber nipples for babies' bottles
TIS 980-2552 Natural rubber latex concentrate
TIS 1025-2539 Babies' dummies
Single-use medical examination gloves - P.1: Specification for gloves made from
TIS 1056-2556
rubber latex or rubber solution
TIS 1425-2540 Latex foam rubber mattresses
Flexible cellular polymeric materials - Sponge and expanded cellular rubber

TIS 1895-2542
products -Specification - P.1: Sheeting
Rubber condoms – Guidance on the use of 4074 in quality management of natural

TIS 2352-2550
latex rubber condoms
TIS 2353-2550 Rubber condoms for clinical trials measurement of physical properties
TIS 2476-2552 Household rubber gloves
TIS 2505-2553 Rubber gloves for food industry
TIS 2556-2554 Rubber threads – Specification
TIS 2577-2556 Rubber threads - Methods of test

109

TIS 2627-2558
rubber latices by titration (cyanide-free method)
TIS 2658-2558
rubber latex by titration
Medical gloves made from natural rubber latex - Determination of water-
TIS 2659-2558
extractable protein using the modified lowry method
TIS 2725-2559 Rubber finger cots
TIS 2741-2559 Natural rubber latex foams for pillows
TIS 2747-2559 Natural rubber latex foams for mattresses
TIS 2633-2564 Natural Rubber Latex Concentrate - Determination of alkalinity
TIS 2634-2564 Rubber, Natural Latex Concentrate-Determination of KOH Number
TIS 2640-2565 Rubber latex, natural, concentrate - determination of volatile fatty acid number
TIS 3373-2565 Natural rubber latex coagulant: Formic acid
TIS 131-2523 Rubber slippers
TIS 361-2524 Sealing compound for batteries
TIS 505-2541 Rubber hot water bags
TIS 542-2549 Reflective thermoplastic road marking material
TIS 570-2528 Elastic webbing
TIS 633-2531 Rubber rolls for paddy dehuskers
TIS 697-2530 Weather strips for automobile
TIS 749-2531 Rubber soles
TIS 800-2545 Weather strips for automobile
TIS 809-2531 Rubber boots
TIS 886-2559 Rubber bands
TIS 893-2532 Rubber brake blocks for rice whitener machine
TIS 916-2532 Castors for furniture: Rubber wheel
TIS 940-2550 Balls for soccer
TIS 941-2550 Balls for basketball
TIS 942-2550 Balls for volleyball
TIS 947-2559 Automotive rubber mats
TIS 1213-2537 Erasers
TIS 1240-2537 Industrial wheels for non-powered equipment: Rubber tyre
TIS 1241-2537 Industrial castors for non-powered equipment: Rubber tyre
TIS 1819 2-2542 Infusion equipment for medical use - P.2: Closures for infusion bottles
Mechanical contraceptives - Reusable natural and silicone rubber contraceptive

TIS 1832-2550
diaphragms - Requirements and tests
TIS 2272-2549 Tracheal tubes

110
TIS 2329-2550 Balls for futsal
TIS 2377-2559 Rubber flooring
TIS 2378-2559 Rubber paving blocks
TIS 2379-2551 Rubber seals for concrete joints
TIS 2556-2561 General purpose rubber thread – Specification
TIS 2577-2561 Rubber thread - methods of test
TIS 2666-2563 Chicken plucker rubber fingers
TIS 2727-2559 Rubber wiper blades
TIS 2949-2562 Rubber playground surfacing

Rubber hoses and hose assemblies for liquefied petroleum gas in motor vehicles-
TIS 1726-2563
specification
TIS 2682-2563 Rubber granules for synthetic surfaces
Male condoms - requirements and test methods for condoms made from synthetic
TIS 3040-2563
materials
TIS 3041-2563 Female condoms - Requirements and test methods
Rubber hoses and tubing for fuel circuits for internal combustion engines -
TIS 3053 1-2563
Specification - Part 1: Diesel fuels
Rubber and plastics hoses and hose assemblies for Automotive air conditioning
TIS 3054 2-2563
- specification - Part 2: refrigerant 134a
TIS 3052-2563 Rubber railway level crossing panel
TIS 237-2564 Rubber ring for water pipe
TIS 3387-2565 Rubber radiation shields for x-ray and gamma–ray
TIS 3011-2562 Tactile rubber flooring for visually impaired persons
TIS 367 1-2532 Automobile tyres - P.1: performance and testing
TIS 367 2-2532 Automobile tyre - P.2: dimensions and load capacity
TIS 571-2528 Bicycle tyre
TIS 651-2529 Tubes of automobile tyres
TIS 652-2529 Bicycle rubber inner tubes
TIS 682-2540 Motorcycle tyres
TIS 683-2530 Motorcycle rubber inner tubes
TIS 683-2562 Inner tubes for motorcycles and mopeds
TIS 1283-2538 Rotary slashers
TIS 1076-2535 Linch pins for agriculture wheeled tractors
TIS 2301-2549 Aircraft tire
Rubber tread compound for hot (conventional) retreading of commercial vehicles

TIS 2478-2552
tyres
TIS 2506-2553 Precured tread for retreading of commercial vehicles tyres
TIS 2668-2558 Forklift solid tyres

111
TIS 2718-2558 Pneumatic tyres for motor vehicles and their trailers
TIS 2719-2558 Pneumatic tyres for commercials vehicles and their trailers
TIS 2720-2558 Pneumatic tyres for motor L-category vehicles
TIS 2721-2559 Rolling sound emission adhesion on wet surfaces and rolling resistance
TIS 2978-2562 Retreaded pneumatic tyres for motor vehicles and their trailers
TIS 2979-2562 Retreaded pneumatic tyres for commercial vehicles and their trailers
TIS 2980-2562 Pneumatic tyres for agricultural vehicles and their trailers
TIS 652-2562 Bicycle rubber inner tubes
TIS 1480-2563 Sugarcane whole stalk planter for agricultural rubber-tire wheeled tractor
TIS 3012-2563 Sugarcane grabber for agricultural rubber-tire wheeled tractor
TIS 3123-2563 Tyres - coast - by methods for measurement of tyre-to-road sound emission
Passenger car, commercial vehicle, truck, and bus tyres - Methods for measuring
TIS 3124-2563
snow grip performance - Loaded new tyres
Passenger car, truck and bus tyre rolling resistance measurement method -
TIS 3125-2563
Single point tests and correlation of measurement results
TIS 3067-2563 Coding for radio frequency identification (RFID) tyre tags
TIS 3066-2563 Radio frequency identification (RFID) tyre tags

Tyres - Electrical resistance - Test method for measuring electrical resistance of
TIS 3161-2564
tyres on a test rig
Pneumatic tubes for automotive vehicles - Technical requirements and test
TIS 3162-2564
methods
TIS 3163-2564 Conformance test methods for RFID enabled tyres
TIS 3164-2564 Radio frequency identification (RFID) tyre tags - Tyre attachment classification
TIS 3160 1-2564 Bicycle tyres and rims - Part 1: Type designation and dimensions
TIS 3160 2-2564 Bicycle tyres and rims - Part 2: Rims

TIS 3210 11- Agricultural tractors-test procedures-part 11: steering capability of wheeled
2564 tractors
TIS 3224 1-2564 Definitions of some terms used in the tyre industry - Part 1: Pneumatic tyres
TIS 3227-2564 Agricultural rubber-tire wheeled tractor: power take-off type
TIS 124-2518 Flat rubber belt for power transmission
TIS 146-2556 Classical V-belts for power transmission
TIS 147-2530 Conveyor belts
TIS 237-2552 Rubber ring for water pipe
TIS 642-2560 Rubber hoses, textile-reinforced, for compressed air — Specification
Rubber hoses and tubing for cooling systems for internal-combustion engines —
TIS 658-2560
Specification
TIS 746-2560 Water suction and discharge rubber hoses

112
TIS 811-2531 Automotive V-belts
TIS 839-2558 Hydraulic brake hose for road vehicles: Rubber hose
TIS 895-2532 Liquefied petroleum gas rubber hose: Vapor phase
TIS 947-2559 Automotive rubber mats
TIS 951-2533 Rubber bridge bearings
Rubber insulated cables - Rated voltages up to and including 450/750 V - P. 1:

TIS 955 1-2551
General requirements
Rubber insulated cables - Rated voltages up to and including 450/750 V - P.2:
TIS 955 2-2553
Test methods

TIS 955 3-2551
Heat resistant silicone insulated cables

TIS 955 4-2551
Cords and flexible cables
Rubber insulated cables - Rated voltages up to and including 450/750 V - P.5: Lift
TIS 955 5-2554
cables

TIS 955 6-2554
Arc welding electrode cables

TIS 955 7-2554
Heat resistant ethylene-vinyl acetate rubber insulated cables

TIS 955 8-2554
Cords for applications requiring high flexibility
TIS 1055-2556 Rubber hoses for liquefied petroleum gas in liquid phase
TIS 1062-2558 Gas welding equipment - Rubber hoses for welding, cutting and allied processes
TIS 1079-2535 Concrete joint filler, sponge rubber and cork
TIS 1086-2555 Rubber hoses for petroleum products: Fuel dispensers
TIS 1135-2544 Rubber waterstops
TIS 1144-2560 Rubber hoses and hose assemblies for saturated steam — Specification
TIS 1184-2558 Textile - reinforced hydraulic rubber hoses
TIS 1210-2558 Rubber hoses for petroleum products: Oil suction and discharge
TIS 1321-2539 Rubber and plastics hose - Determination of adhesion between components
TIS 1332-2539 Rubber and plastics hoses and hose assemblies - Hydrostatic testing
Rubber hoses and hose assemblies for liquefied petroleum gas in motor vehicles
TIS 1726-2541
- Specification
TIS 1899-2542 Thermoplastics pipes and fittings for hot and cold-water systems
TIS 2477-2552 Rubber weir bag
TIS 2507-2553 Marine rubber fenders: D-shape and square shape
Rubber hoses and hose assemblies for washing-machines and dishwashers -

TIS 2557-2554
Specification for inlet hoses
113
TIS 2579-2552 Marine rubber fenders: cylindrical shape and V - shape
TIS 2583-2556 Rubber sheets for reservoir lining
TIS 2584-2556 Rubber sheets for livestock
TIS 2667-2558 Rubber rail pads
TIS 2682-2558 Rubber granules for synthetic surfaces
TIS 2683-2558 Synthetic surfaces

Rubber hoses and tubing for air and vacuum systems for internal-combustion
TIS 2696-2560
engines - Specification
Rubber or plastics hoses and hose assemblies -- Hydraulic-pressure impulse test
TIS 2654-2558
without flexing
TIS 2655-2558 Rubber and plastics hoses - Method of test for flammability
Rubber and plastics hoses and tubing - Determination of transmission of liquids

TIS 2656-2558
through hose and tubing walls
Rubber and plastics hoses and hose assemblies - Guidelines for selection,
TIS 2657-2558
storage, use and maintenance
Rubber hoses, textile-reinforced, for general-purpose water applications -
TIS 2693-2558
Specification
Rubber hoses and hoses assemblies-wirebraid-reinforced hydraulic types for oil-

TIS 2694-2558
based or water-based fluids - Specification
TIS 2731-2559 Natural rubber modified asphalt cement
TIS 2739-2559 Futsal rubber flooring
Road vehicles - Elastomeric boots for cylinders for drum type hydraulic brake
TIS 2810-2560 wheel cylinders using a non-petroleum base hydraulic brake fluid (Service
temperature 120 °C max.)
Road vehicles - Elastomeric boots for drum-type, hydraulic braking wheel

TIS 2811-2560 cylinders using a non-petroleum base hydraulic brake fluid (Service temperature
100 °C max.)
Road vehicles - Elastomeric cups and seals for seals for cylinders for hydraulic
TIS 2812-2560 braking systems using a non-petroleum base hydraulic brake fluid (Service
temperature 70 °C max.)
Road vehicles - Elastomeric cups and seals for cylinders for hydraulic braking
TIS 2813-2560 systems using a non-petroleum base hydraulic brake fluid (service temperature
120 °C max.)
Road vehicles - Elastomeric seals for hydraulic disc brake cylinders using a non-
TIS 2814-2560
petroleum base hydraulic brake fluid (service temperature 150 °C max.)
Road vehicles - Elastomeric seals for hydraulic disc brake cylinders using a non-
TIS 2815-2560
petroleum base hydraulic brake fluid (Service temperature 120 °C max.)
Road vehicles - Elastomeric seals for hydraulic disc brake cylinders using a
TIS 2816-2560
petroleum base hydraulic brake fluid (service temperature 120 °C max.)
TIS 14061 1-
Sustainable Forest Management System Part1 Specification
2559
TIS 2423-2552 Rubberwood sawn timber
114
TIS 2881-2560 Water Mattresses from Rubber Bags
GMP Good Manufacturing Practices
STR Standard Thai Rubber

Soya TAS 4903-2019 Good Agricultural Practices for Soybean Seed Production
TAS 8802-2015 Soybean Meal
TAS 4701-2013 Soybeans
TIS 176-2561 Edible Soybean Oil
TIS 484-2542 Soybean Fatty Acid
TIS 750-2553 Soybean Oil for Resin Industries
TIS 1018-2533 Soymilk Or Soya Bean Milk

Wood FSC Forest Stewardship Council
TIS 178-2549 Veneer Plywood
TIS 192-2549 Wood-based Panel Doors
TIS 193-2519 Solid Wood Parquet Strips with Rectangular Face
TIS 421-2525 Sawn Timber: General
TIS 422-2530 Teak Conversions
TIS 423-2530 Sawn Hardwood Timber (nonteak)
TIS 424-2530 Structural Timber
TIS 497-2526 Kiln-Dried Sawn Timber
TIS 504-2527 Wooden Frames and Panel Frames for Doors and Windows
TIS 516-2531 Impregnated Sawn Timber by Cca Compositions
TIS 588-2528 Wooden Flat Pallets
TIS 724-2530 Teak Spliced Veneer
TIS 876-2547 Flat Pressed Particleboards
TIS 876-2565 Flat Pressed Particleboards
TIS 877-2547 Extruded Particleboards
TIS 963-2533 Tongue and Groove Wood Flooring Strips: Nonteak
TIS 994-2533 Wood Flooring Strips with Finger Jointing: Nonteak
TIS 1106-2535 Mosaic Parquet Panels: Nonteak
TIS 1107-2535 Plastics Laminated Plywood for Concrete Formwork
TIS 1138-2536 Solid Wood Parquet Strips: Nonteak
TIS 1221-2537 Solid Wood Parquet Strips: Teak
TIS 1301-2538 Tongue And Groove Solid Wood Flooring Strips: Teak
TIS 1302-2538 Solid Wood Flooring Strips with Tongue-and-Groove Sides and Ends: Teak
115
TIS 1367-2539 Solid Wood Flooring Strips with Tongue-and-Groove Sides and Ends: Nonteak
TIS 2115-2545 Pre-Finished Multiply Wood Flooring
TIS 2158-2547 Solid Wood Flooring Strips with Finger Jointing: Teak
TIS 2861 1-2560 Forest Products Supply Chain Management

TIS 14061 1-
Sustainable Forest Management System Part1 Specification
2559
TIS 3450-2565 Solid Biofuels - Graded Wood Chips

TACSF = Thai Agricultural Commodity and Food Standard
TAS = Thai Agricultural Standard
TIS = Thai Industrial Standard

116
Annex 10. Defining SMEs

Table A50. Comparison of criteria for defining SMEs in Thailand and the EU
Criteria Thailand Thailand (service EU

(Manufacturing) providers, wholesalers,
or retailers)
Micro- Employees NA NA 10
enterprise
Balance sheet NA NA 350,000Euros
(12,722,366THB)
Turnover NA NA 700,000Euros
(25,444,733THB)
Revenue NA NA NR
Small Employees <50 <30 50

enterprise
Balance sheet NR NR 4,000,000Euros
(145,398,474THB)
Turnover NR NR 8,000,000Euros
(290,796,949THB)
Revenue 100,000,000THB 50,000,000THB NR
(2,750,000Euros) (1,380,000Euros)
Medium Employees 50-100 30-100 250

enterprise
Balance sheet NR NR 20,000,000Euros
(726,992,372THB)
Turnover NR NR 40,000,000Euros
(1,453,984,745THB)
Revenue 100,000,000 - 50,000,000 - 300,000,000 NR
150,000,000THB THB
(2,750,000 - 4,130,000 (1,380,000 -
Euros) 8,260,000Euros)
116
10.1 Defining SMEs in Thailand
According to the Small and Medium Enterprises Promotion Act, B.E. 2543 (2000)
• A small or medium enterprise is the enterprise with the level of employment, value of fixed assets or paid-
up registered capital as prescribed in the Ministerial Regulations.
• Enterprise means product manufacturing business, service rendering business, wholesale business, retail
business or any other businesses prescribed by the Minister by publishing in the Government Gazette.
According to the Ministerial Regulations on the Designation of the Characteristics of Small and Medium Enterprises
Promotion Act B.E. 2562 (2019) small enterprises refer to enterprises with the following characteristics:
• Enterprises which hire no more than 50 employees in their product manufacturing business, and whose
annual revenue does not exceed 100 million baht, and
• Enterprises which are service providers, wholesalers, or retailers, hiring not more than 30 employees and
generating an annual revenue of not more than 50 million baht.
While medium enterprises refer to enterprises with the following characteristics:

117
• Enterprises which hire more than 50, but no more than 100, employees, in their product manufacturing
business, and whose annual revenue amounts to more than 100 million baht but does not exceed 150
million baht, and
• Enterprises which are service providers, wholesalers, or retailers hiring more than 30, but no more than
100, employees, and generating an annual revenue of more than 50 million baht but no more than 300
million baht.
10.2 Defining SMEs in the EU

EUDR Article 2(30) SMEs’ mean micro, small and medium-sized enterprises as defined in Directive 2013/34/EU35
(Article 3)
• Article 3(1) Micro-undertaking (enterprise), balance sheet dates do not exceed the limits of at least two of
the three following criteria: (a) balance sheet total: EUR 350,000; (b) net turnover: EUR 700,000; (c) average
number of employees during the fiscal year: 10.
• Article 3(2) Small undertaking, balance sheet dates do not exceed the limits of at least two of the three
following criteria: (a) balance sheet total: EUR 4,000,000; (b) net turnover: EUR 8,000,000; (c) average
• Article 3(3) Medium-sized undertakings shall be undertakings which are not micro-undertakings or small
undertakings and which on their balance sheet dates do not exceed the limits of at least two of the three
following criteria: (a) balance sheet total: EUR 20,000,000; (b) net turnover: EUR 40,000,000; (c) average
118
Annex 11. Notes from interviews conducted as part of the assignment

Europeaid/138778/Dh/Ser/Multi Siea 2018 Lot 1: Sustainable Management of Natural Resources and Resilience

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EuropeAid/138778/DH/SER/Multi SIEA 2018

Assessment of the potential impact of the

Assessment of the potential impact of the proposal for

Landell Mills International

The Old Station House

15a Main Street

Framework Contract EuropeAid/138778/DH/SER/Multi Framework Services for the

Specific contract number: Contract #300054988

Name of project: Assessment of the potential impact of the proposal for an EU

Start/end date: 15 January 2023 – 8 July 2024

Contracting Authority: Delegation of the European Union to Thailand

Task Manager: Saroj Srisai

Contractor: Landell Mills International

QUALITY ASSURANCE STATEMENT

Version: DRAFT FOR DISSEMINATION

Prepared by: Name Position

David Gritten Team Leader

Weeraphart Khunrattanasiri Thailand-based expert

Checked by: David Gritten Team Leader

Matilde Anttila Project Executive, Landell Mills

Harriet Bull Manager, Framework Division, Landell Mills

3.3.3. Potential impacts - SMEs 54

Figure 1 Assessment framework for the assignment............................................................................... 14

Table 1 Overview of the stakeholders interviewed for the assessment .................................................. 17

AMAF ASEAN Ministers on Agriculture and Forestry

HS Harmonised Commodity Description and Coding System

The desk review covered the following overlapping areas:

i. Due diligence analysis

Opportunities and challenges

Ways forward – potential cooperation and support measures

1. Increase legal and deforestation-free trade flows

It is suggested that EU agencies would help to achieve these through:

1. Awareness raising campaign:

Suggested priority actions for the RTG include:

2.1. Assessment framework

2.2. Desk review

i. Due diligence analysis

iii. Legal analysis

i. Due diligence analyses

The due diligence analysis covered:

ii. Forest and land use data and mapping

The forest and land use data analysis covered:

iii. Legal analyses

iv. Stakeholder analysis

v. Supply chain analysis

The supply chain analysis covered:

vi. Trade data analysis

The trade data analysis covered:

vii. Literature review

• Existence of due diligence systems required for each commodity.

Stakeholder group Organisation # Individuals

Government Department of Foreign Trade (DFT) 2

Green Invest Asia (GIA) 2

Rubber Network Council

Rubber Farmer Institute Network (RFIN) and rubber smallholder 1

Thailand Rubber Network

Thai Timber Association (TTA) 5

Private sector Private Forest Plantation Cooperative Limited (PFPC) 1

3.1.1. EUDR context

3.1.2. Thailand context

3.1.2.1 Thailand’s forests