After the Moratorium: How to ensure that Brazilian soy is not associated with deforestation?

In August 2025, the Administrative Council for Economic Defense (CADE) ordered the immediate suspension of the Soy Moratorium, an agreement signed in 2006 to prevent the purchase of grains produced in areas deforested in the Amazon after July 2008. The decision, which opened an investigation into associations such as Abiove and Anec and major global trading companies, was based on the interpretation that the pact could constitute an anticompetitive arrangement, limiting free competition in the international soybean trade. The measure had a strong impact on the sector and the global soybean market. For organizations such as Aprosoja-MT, the end of the moratorium represented the dismantling of an unfair barrier to producers in the Legal Amazon. The Ministry of the Environment, the Federal Public Prosecutor's Office, and environmental organizations such as Greenpeace and the World Wide Fund for Nature (WWF) reacted with concern, highlighting the risk of environmental setbacks and noting that the pact helped consolidate Brazil's image as a reliable supplier in markets increasingly focused on sustainability.

The figures highlight the positive effects of the moratorium in terms of significantly reducing deforestation in the Amazon biome. Between 2002 and 2008, before its implementation, soy-producing municipalities in the Amazon deforested an average of 10.629 km² per year; after the pact, this figure fell to 2.997 km² per year, a 72% reduction [1]. Studies published in prestigious international journals confirm this impact. The study by Gibbs et al. (2015), published in the journal Science, showed that, before the moratorium, approximately 30% of soybean expansion occurred in recently deforested areas, while after the agreement, this figure fell to just 1%. The data demonstrate that the moratorium was effective in directing soybean expansion into already cleared areas, contributing to the conservation of native forests, especially in the Amazon biome.

But the positive effects also coexisted with criticism. For many producers, especially in Mato Grosso, the moratorium represented a form of territorial discrimination, as it restricted soybean expansion solely to the Amazon, ignoring other regions with native vegetation, such as the Cerrado and potential agricultural frontiers. This resulted in what was considered excessive pressure on producers in certain areas. Questions about the transparency of the governance process and the predominance of large trading companies and international NGOs in decision-making also gained traction. CADE's Technical Note 18/2023 echoed some of these criticisms, raising questions about market entry barriers, price impacts, and possible antitrust violations. It was in this context of tension that the decision to suspend it took shape, leaving open what will replace the pact that for almost two decades has contributed significantly to reducing deforestation in Brazil [for more details, see: TECHNICAL NOTE No. 18/2023/DEE/CADE].

The vacuum left by the moratorium offers socio-environmental certifications as an alternative, which could now accelerate the expansion of private labels as a way to fill the governance gap. Without a nationwide sectoral pact, some international markets tend to demand more guarantees through internationally recognized certification schemes capable of ensuring verifiable and auditable criteria. The Round Table on Responsible Soy (RTRS) is an example of an international certification model in this regard, covering multiple criteria and offering buyers the ability to track production, seeking to ensure transparency for global chains that use soy as an input.

When analyzing the country where the units of companies purchasing RTRS-certified soybeans and corn in 2024 are located, it is clear that most are headquartered in Europe, which accounts for the largest volumes purchased. This prominence stems largely from the presence of major grain traders in the Netherlands and the United Kingdom, which together account for over 60% of global RTRS adoption. Europe's leadership highlights how regulatory pressure and the demand for deforestation-free supply chains remain strongly linked to consumption in the bloc. Brazil ranks next as the second-largest hub of purchasing companies, with 1,9 million tons (25,53% of the total), reflecting both its relevance as a major producer and the need to maintain access to sustainability-sensitive markets. The participation of Latin American countries such as Argentina, Ecuador, and Peru, albeit on a smaller scale, reinforces the gradual dissemination of the certification model in the region. This distribution indicates that, given the absence of a robust sectoral pact following the suspension of the Soy Moratorium, private certification tends to consolidate itself as a key governance instrument, especially in the dialogue between Brazilian producers and highly regulated international markets.

Table 1 – Country of location of companies purchasing RTRS certified soybeans and corn in 2024

Source: RTRS (2025)

Source: RTRS (2025)

Figure 1 - Main purchasing countries in 2024 of RTRS certified soybeans and corn

In addition to the RTRS, there are several soy certification models, such as ProTerra, ISCC, and organic standards, among others. These systems present challenges and opportunities that unfold across three core dimensions: environmental, social, and market.

Table 1 – Dimensions of soybean certification in Brazil

Source: RTRS (2025)

The challenges identified in Brazilian soy certification reveal a common pattern: high costs, lack of technical assistance, and complex processes that limit widespread adoption. Environmentally, the requirement for zero deforestation and sustainable agricultural practices imposes significant technical and financial barriers, especially on smaller properties and in contexts where legal deforestation still exists under Brazilian law. Socially, criteria such as combating slave labor, promoting decent work, and ensuring workplace safety represent important advances, but require additional investment in management, technical assistance, and infrastructure. These requirements primarily challenge small and medium-sized producers, who lack the means and control mechanisms to demonstrate environmental compliance and social responsibility to access higher-value chains. At the market level, the costs of individual audits and verifications remain a barrier, differentiating large exporters, who can absorb these costs, from smaller producers, who find it more difficult to obtain internationally recognized certifications.

Furthermore, there is the cost associated with maintaining the credibility of these certification instruments by the responsible entities themselves. Cases of failures in accreditation processes, as occurred in the carbon credit sector, have shown how deviations can quickly undermine the trust of markets and consumers. This reputational risk is crucial, as certifications depend directly on the perception of robustness and independence of their audits. In this sense, the Soy Moratorium functioned as a simpler and more direct control mechanism, with fewer intermediaries and uniform rules applied across the entire chain. In contrast, international certification models, in seeking to meet global standards, often end up overlapping or even conflicting with national legislation, raising questions about their legitimacy and alignment with local production realities.

On the other hand, there are opportunities arising from the greater adoption of certification with international standards, which may suggest the possibility of a strategic reconfiguration of Brazilian soybeans. In addition to access to traditional markets in the European Union, certification consolidates reputation and can facilitate entry into new markets, as well as access to green credit lines, increasingly relevant in agricultural financing. In the near future, soybeans' role as an input in the production of sustainable aviation fuels (SAF) and maritime fuels expands their potential for insertion into global energy chains, in sectors that require rigorous proof of sustainability. In this sense, robust and widely accepted international certifications offer not only traceability and credibility standards but also the conditions for Brazilian soybeans to position themselves competitively in highly regulated markets.

The harmonization of standards between national and international certifications gains relevance with the entry into force of the European Regulation to Combat Deforestation (EUDR), scheduled for 2026. By aligning socio-environmental criteria with this regulatory framework, certified soy strengthens its competitive position in the global market and responds to the growing demand for traceable, deforestation-free supply chains. This movement indicates that certification is no longer a differentiator restricted to specific niches, but rather a consolidated requirement for governance and access to regulated markets.

In this context, Brazil has also been advancing in the development of public platforms, such as Agro Brasil + Sustentável, which seeks to establish itself as an official alternative for guaranteeing good agricultural practices. The proposal is to offer a national solution for traceability and certification, integrating information on environmental, social, and production compliance in a public database. Unlike private certifications, which are primarily aimed at meeting the demands of specific markets, Agro Brasil + Sustentável aims to create a governance standard recognized by the Brazilian state, capable of dialoguing with international requirements—such as the EUDR—and, at the same time, reducing the regulatory fragmentation faced by producers. If well implemented, it can function as a strategic instrument to provide predictability to rules, legitimize national production, and strengthen the country's position in trade negotiations. The challenge, however, lies in ensuring that the platform is robust, transparent, and reliable enough to be accepted by international buyers, avoiding the risk of becoming merely a bureaucratic seal, lacking credibility in the global market.

This dynamic is directly connected to the regulatory vacuum left by the suspension of the Soy Moratorium. While the pact served as a collective instrument to condition the expansion of production in the Amazon, certification systems now offer verifiable and auditable criteria that fulfill a similar function of providing predictability and credibility to value chains. The relationship between these instruments shows that, in the absence of broad sectoral pacts, private certification tends to assume a leading role as a governance mechanism, serving as a bridge between Brazilian producers and international markets increasingly guided by environmental and social rules.

The end of the Soy Moratorium ushers in a period of greater uncertainty, but also of potential institutional redefinition. For nearly two decades, the voluntary pact guided production expansion into already open areas and helped consolidate a governance model that legitimized Brazil in sustainability-sensitive markets. Its suspension, however, exposed structural limitations: the reliance on private agreements, the tension between free competition and environmental commitments, and disputes between producers, the government, and civil society. The challenge now is to prevent the regulatory vacuum from weakening already achieved socio-environmental achievements and, at the same time, find mechanisms that provide predictability to the rules of the game, an essential condition for producers and buyers.

In this scenario, private certifications also raise dilemmas. On the one hand, they ensure internationally recognized standards, offer traceability, and can open up higher-value markets, especially in the European Union. On the other, their voluntary nature and dependence on external entities tends to limit the scale of adoption, concentrating it on large, resource-rich producers. This logic risks transforming certification into a niche, incapable of encompassing all of Brazil's production. Furthermore, there is the so-called "spillover effect": prime, productive areas tend to become certified, while marginalized production expands into more fragile areas, including forests, deepening inequalities and territorial pressures.

Therefore, this reflection cannot ignore the role of national public standards. Initiatives like Agro Brasil + Sustentável seek to build an official alternative for traceability and certification, integrating socio-environmental information into a public database with state legitimacy. If robust, transparent, and internationally recognized, this platform can reduce regulatory fragmentation and offer a more comprehensive response than isolated private certifications. The risk, however, is that it will become merely a bureaucratic seal, lacking real acceptance in buyer markets.

China deserves special attention in this debate. Responsible for 58,65% of Brazilian soybean exports, the Asian country is often seen as a safety valve in the face of stricter European Union demands. But the reality is more complex. Dependence on such a concentrated buyer could reduce Brazil's bargaining power and increase strategic vulnerabilities in the medium term. Furthermore, China itself has been gradually incorporating concerns related to food security, the global image of its supply chains, and pressure from international investors. Ignoring this dynamic would be a mistake.

The future of Brazilian soybeans will depend not only on its ability to meet the most demanding sustainability demands of markets, but also on understanding that even strategic partners like China may, sooner or later, align themselves with this movement. The real challenge lies in building governance that goes beyond the logic of certified niches and mere adaptation to external demands, to consolidate a national model capable of ensuring competitiveness, predictability, and legitimacy in a global market that no longer tolerates the dissociation between production and conservation.

[1] For more details, read the text “Monitoring of the Soy Moratorium through satellite images: Supplementary Material”

References and recommended readings:

ADMINISTRATIVE COUNCIL FOR ECONOMIC DEFENSE - CADE. Technical Note 18 – SEI_CADE – 1285202 – 087000002702018-72. 2023. Accessed on: 18 Aug. 2024.

STATE Aprosoja MT is considering reporting the soybean moratorium to CADE. Agro Estadão. Accessed on: August 18, 2024.

FORBES AGRO. Government agencies disagree on the soybean moratorium, increasing risks for traders. Forbes Brasil, August 22, 2025. Accessed on: September 11, 2025.

GIBBS, H.K.; RAUSCH, L.; MUNGER, J.; SCHELLY, I.; MORTON, D.C.; NOOJIPADY, P.; SOARES-FILHO, B.; BARRETO, P.; MICOL, L.; WALKER, N.F. Brazil's Soy Moratorium: Supply-chain governance is needed to avoid deforestation. Science, vol. 347, no. 6220, p. 377-378, 2015.

SOYBEAN MORATORIUM. Home. Accessed on: August 18, 2024.

ROUND TABLE ON RESPONSIBLE SOY (RTRS). Overview 2024: Global Adoption of RTRS Certified Material. May 15, 2025. Accessed: September 11, 2025.

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