Retail Soy Group coordinates response to potential elimination of the Amazon Soy Moratorium

The Retail Soy Group, represented by 3Keel Director, Will Schreiber, issued a letter on Friday 5 September for World Amazon Day, to the major Brazilian exporters of soy, requesting they maintain their commitment to protect the Amazon Soy Moratorium (ASM). 

The ASM is a key agreement for Amazon rainforest protection. Brazil is the world’s largest exporter of soy – mainly for animal and fish feed – and in the early 2000s, production was threatening the Amazon rainforest. In 2006, a landmark conservation move delivered a moratorium on supplies from the region. Stakeholders including global companies, soy traders, farmers, conservationists, and the Brazilian government agreed to a framework and monitoring system that would ensure  soybeans from areas that were deforested in the Amazon after 2008 would not be able to enter the global market. In 2016, the ASM was implemented ‘indefinitely’ and according to a 2021 report from the WWF, was widely seen as a success, with less than 2% of deforestation linked to soy by 2018.

In late August 2025, Brazil’s competition authority (CADE) announced that it was giving traders 10 days to suspend the moratorium and that it was launching an investigation into the agreement, citing concerns that the participating companies were acting illegally by blocking non-compliant farms from entering the market. The suspension was announced before any investigation was carried out, and comes at the same time as other efforts are underway to discourage continued participation by the private sector.

Conservation groups and the soy buying and exporting organisations being targeted have challenged the move. Just days before entering into force, the Brazilian federal court paused CADE’s suspension order until a more thorough review and investigation occurred. 

The Retail Soy Group has now coordinated and sent a cross-sector letter urging the five largest soy exporters – ADM, Bunge, Cargill, Louis Dreyfus, and COFCO – to maintain their existing commitments to the Amazon, including the 2008 cut-off date. 

Will Schreiber, 3Keel Director and Representative of the Retail Soy Group, says, “Maintaining what works is common sense. Of course, solutions to deforestation go beyond restrictions: we need to invest in and reward the people and communities providing ecosystem services so that there is an equitable shared benefit and value. But stepping backwards without credible alternatives isn’t just risky—it’s reckless.”

The Retail Soy Group’s letter: 

We are writing to you at a critical moment for the future of the Amazon Soy Moratorium (ASM) – an initiative your companies have championed, protecting the Amazon for nearly two decades and rightly hailed as one of the most significant conservation measures of this century. Protecting the Amazon remains a crucial part of our collective efforts to meet our climate goals and maintain Brazil’s international credibility as being a responsible pillar within global agriculture. 

August’s announcement by Brazil’s competition authority (CADE) to suspend the ASM poses a serious threat to this vital agreement. We welcome your efforts to appeal the decision and to uphold its legality. Even though a temporary injunction was put in place concerning the immediate implementation of the order, action is needed to remove any market uncertainty over this time regarding the protections of this vital ecosystem. Importantly, CADE itself confirmed that companies may continue to apply the 2008 cut-off date independently and in line with national legislation.

In light of this, we urge your company to: 

1. Publicly reaffirm the 2008 cut-off date for the Amazon for all your soy purchases – direct and indirect – in the Amazon biome, consistent with your own individual commitments, policies and legal obligations. 
2. Maintain your compliance – Should any suspension of the Amazon Soy Moratorium occur, we expect you to be prepared to immediately deploy an interim compliance measure on an individual company basis until a longer-term solution is secured. 

Our companies remain committed to sourcing that eliminates deforestation and complies with competition law. In the absence of a sector-wide mechanism like the ASM, we* will evaluate each company’s performance individually against our own individual procurement policies. These typically reflect the widely recognised independent benchmarks for responsible sourcing of soya, which include the 2008 cut-off date in the Amazon. 

*For the avoidance of doubt, this letter does not constitute an agreement between competitors: each addressee is expected to determine its own approach independently, and each signatory will evaluate supplier performance individually and in line with its own procurement policies.