The UK Government has announced plans to strengthen its approach to tackling deforestation linked to British supply chains.
Under the proposals, businesses in Great Britain using certain forest-risk commodities and wood products could be required to carry out supply chain due diligence, collect product-origin information and report on their compliance.
A mandatory timber due diligence framework has operated across the UK since 2013. The Government now intends to build on this system to further reduce the UK’s contribution to global deforestation.
The new regime is expected to be introduced in 2027, although the detailed requirements will be subject to consultation and further legislation. This article aims to summarise the recently published policy paper of the UK’s approach to deforestation regulations.
Which Businesses Could be Affected?
The proposed requirements would apply to businesses in Great Britain with an annual turnover of more than £1 million that use specified forest-risk commodities or products made from them.
The commodities expected to be covered are:
- Wood
- Cattle
- Cocoa
- Coffee
- Palm oil
- Rubber
- Soy
- Certain derived products, including chocolate and furniture, are also expected to fall within scope.
This means the rules could affect businesses across a wide range of sectors, including food and drink, retail, manufacturing, hospitality, construction and furniture.
What Would Businesses Need to Do?
Businesses within scope would be expected to establish a due diligence system demonstrating that relevant commodities and products were produced in accordance with applicable laws in their country of origin.
The proposed requirements are likely to include:
- Identifying relevant commodities and products within the supply chain
- Collecting information about their origin
- Obtaining geolocation data for production areas
- Assessing and addressing supply chain risks
- Keeping evidence of compliance
- Reporting on due diligence activity
Although the final details have not yet been confirmed, affected businesses may need significantly greater visibility beyond their immediate suppliers.
Alignment with the EUDR
The Government aims to make the Great Britain regime broadly consistent with the EU Deforestation Regulation, known as the EUDR.
In particular, the information businesses must collect under the GB system is expected to be similar to the information needed when exporting relevant goods to the EU or moving them into Northern Ireland.
This is intended to reduce regulatory divergence and avoid businesses having to operate completely separate due diligence systems for the GB, Northern Irish and EU markets.
The recently published policy paper, on the GOV.UK website affirms that:
“We aim to make sure GB regulations operate consistently alongside the EU Regulation on Deforestation-free Products (EUDR), so as to support the government’s commitment to protect the UK internal market and support export led growth. We also aim to achieve due diligence consistency for businesses working in both the UK internal market and EU single market.”
However, businesses should not assume that the regimes will be identical. The GB requirements are still being developed and will focus initially on whether products have been produced in compliance with relevant local laws. The Government has indicated that it intends to move towards a wider deforestation-free standard in the future.
Different Rules for Northern Ireland
The EUDR will apply in Northern Ireland as part of the arrangements supporting its access to the EU single market.
UK businesses that place relevant products on the Northern Ireland or EU markets will therefore need to assess whether they have obligations under the EUDR.
Current EUDR application dates are:
- 30 December 2026 for large and medium operators
- 30 December 2026 for micro and small operators dealing in wood products already regulated under the EU Timber Regulation
- 30 June 2027 for most other micro and small operators
Businesses that first place relevant goods on the market will generally carry the main responsibility for ensuring that applicable products are supported by the required due diligence information. Downstream businesses may have reduced obligations depending on their role.
UK Classified as Low Risk
The UK is currently classified as a low-risk country under the EUDR.
This means operators may be able to use simplified due diligence for relevant commodities produced in Great Britain and exported to the EU or moved into Northern Ireland.
However, low-risk status does not remove all obligations. Businesses may still need to gather supply chain information, confirm product origin and submit or retain the required documentation.
Preparation Will Require More Than Supplier Declarations
The direction of travel is clear: businesses using forest-risk commodities will increasingly be expected to understand exactly where their materials come from and demonstrate that they have been sourced legally and responsibly.
Supplier assurances alone may not be enough. Businesses may need traceable, product-specific evidence supported by location data, risk assessments and documented controls.
With EUDR requirements approaching and new GB legislation expected in 2027, businesses should begin assessing their exposure now. Building supply chain visibility early will help reduce the risk of missing information, disrupted trade and costly last-minute compliance work.
