On 23 June 2026, the UK government announced that it will strengthen its approach to tackling global deforestation by moving from a voluntary to a mandatory due diligence system for commodities and products that may be derived from deforestation.
What are the purposes of the proposal?
The specific purpose of the UK’s strengthening of due diligence is to ensure that “forest-risk” commodities and products derived from them are produced in compliance with local legislation in the supply chain.
The general purposes are (1) to minimise the UK’s impact on global deforestation and forest degradation – predominantly from agricultural expansion – that results in the destruction of millions of trees, (2) to reduce the UK’s contribution to greenhouse gas emissions as a consequence of the deforestation, and (3) to assist in halting the global loss of biodiversity.
Which businesses and commodities are affected?
The UK’s proposal is expected to apply to businesses in Great Britain that have an annual turnover of over £1m and which use specified forest-risk commodities – cattle, cocoa, coffee, palm oil, rubber, soy, and wood – and products derived from them including chocolate, furniture, and palm oil derivatives including personal care products.
The UK Government also confirmed that businesses in Northern Ireland (which is in the European Union (EU) single market) will apply the EU Deforestation Regulation (EUDR), adopted in 2023 to reduce regulatory divergence. The EUDR requires businesses that place specified products on the EU market or that export such products from the EU to prove they did not originate from land that was deforested after 31 December 2020.
Some UK businesses are already subject to the EU Timber Regulation, which among other things, prohibits placing illegally harvested timber and timber products on the EU market, and includes due diligence requirements.
When will the regimes come into force in the UK?
The UK Government will hold a consultation on the approach for Great Britain later in 2026. Regulations pursuant to the Environment Act 2021, other legislation, and strengthening of the UK Timber Regulation (derived from the EU Timber Regulation) are expected to be introduced in 2027.
The EUDR will be phased into Northern Ireland law from 30 December 2026. The timing is the same as for Member States of the EU. The EUDR will apply to large and medium “operators” (defined as persons that place relevant products on the EU market or that export them) and any operators covered by the EU Timber Regulation from that date, and to micro and small operators from 30 June 2027.
Is the UK approach the same as the EU approach?
The UK has announced that it will align aspects of its proposal to the EUDR. Subject to the forthcoming consultation, the scope of businesses subject to requirements in the UK will be the same as in the EU. The commodities and products in both approaches will broadly be the same. There are however differences as well as similarities between the UK and the EU approaches.
A major difference is that the UK will initially require commodities and products to be produced in accordance with local laws of businesses in the supply chain (that is, it will apply only to illegal deforestation) before moving to a deforestation-free standard.
The EUDR meanwhile already has a deforestation-free standard. It bars forest-risk commodities and products being placed on the EU market, or being exported from the EU, unless the operator shows that:
its production complies with the relevant country’s legal requirements (such as land use rights and environmental protection laws); and
it is covered by a valid due diligence statement (or a simplified declaration for micro or small primary operators).
The EUDR has been controversial due, among other things to administrative burdens inherent in it, the creation of trade barriers, and potential harm to small farmers in the supply chain. The final version is a delayed and simplified version of the original legislation.
Will the UK legislation and the EUDR increase administrative burdens for businesses in the UK?
The UK legislation and the EUDR will increase administrative burdens for businesses in the UK due to mandatory increased due diligence. Businesses in Northern Ireland will be directly impacted by the EUDR from December 2026. Businesses in Great Britain will be directly impacted by the UK anticipated legislation, probably from some time in 2027.
In addition, businesses in Great Britain will be indirectly impacted by the EUDR because, whilst it is not directly applicable, operators will need to comply with the EUDR’s due diligence and traceability rules when exporting forest-risk commodities and products either to the EU or when moving them to Northern Ireland.
Final thoughts
Whilst the details of the UK’s approach to the more stringent due diligence requirements for the supply chains of commodities and products potentially derived from deforestation have not been set out as yet, it is already evident that the requirements will be more stringent than current requirements. Among other things, businesses may wish to comment on the consultation later this year as well as to monitor the legislative process.
