Royal Golden Eagle (APRIL)

Study finds most deforestation in Indonesian pulp supply hidden from EU rules

A peer-reviewed study of 2015-2022 traceability data finds that 71.45% of recorded deforestation across concessions held by Indonesia's three dominant pulp exporters falls outside the classification used to attribute deforestation directly to wood-pulp production. The exporters covered are Sinar Mas, APRIL (Royal Golden Eagle) and trading house Marubeni, which together control about 96% of Indonesia's pulp capacity. The authors say the gap could raise evidentiary burdens for these groups under the EU Deforestation Regulation.

Why this mattersWider due-diligence gaps in pulp sourcing raise compliance risk under the EU Deforestation Regulation for paper and fibre packaging buyers reliant on Indonesian pulp.

• Sinar Mas, APRIL and Marubeni together control approximately 96% of Indonesia's pulp production capacity and exported 37.19 million tonnes of pulp worth USD 19.69bn between 2015 and 2022.
• Of 359,900 hectares of recorded annual deforestation across traced concessions, only 28.55% (102,765 hectares) was classified as directly linked to wood-pulp production, leaving 71.45% (257,135 hectares) as unclassified 'shadow risk'.
• Sinar Mas exported 18.44 million tonnes (USD 10.30bn) of pulp with 41,697 hectares of deforestation exposure and about 556.7 million tonnes of CO2-equivalent in concession-related emissions.
• APRIL exported 15.89 million tonnes (USD 7.86bn) with 34,464 hectares of deforestation exposure and 133.9 million tonnes of CO2-equivalent in emissions.
• Sinar Mas's emissions intensity was 30.19 tonnes of CO2-equivalent per tonne of pulp, above the sector benchmark of 22.23, versus 8.43 for APRIL.
• Marubeni, exporting 2.86 million tonnes, showed no recorded deforestation exposure or concession-related emissions within the study's analytical boundary.

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