UK deforestation due diligence: a framework, not yet a duty
The UK's regime for forest risk commodities lives in Schedule 17 of the Environment Act 2021 — enacted, but not yet in force, because no implementing regulations have been made. The current government plan, published in June 2026, would introduce a GB Deforestation Regulation in 2027. This page states what is actually the law today, what is proposed, and what has been superseded.
Schedule 17 is a framework — it imposes no duty on its own
Enacted is not the same as in force. Until regulations are made, there is nothing to comply with.
513 Forest-risk-commodity due diligence is a framework in Schedule 17 of the Environment Act 2021. With section 116, it lets the Secretary of State make regulations prohibiting larger businesses from using a forest risk commodity produced on land used illegally, and requiring a due-diligence system and annual reporting — but the duties bite only once those regulations specify the commodities, thresholds and start date. None has been made. The Government’s own current plan expects implementing legislation in Great Britain in 2027.
- 2021–22Defra consultation (16,838 responses)
- DEC 2023Earlier proposal (£50m, 4 commodities)
- 23 JUN 2026Current plan published
- 2027GB legislation expected
A proposed GB Deforestation Regulation
The current government intention: due diligence for GB businesses over £1m turnover, across seven commodities, aligned with the EU.
514 On 23 June 2026 the Government published “The UK’s approach to deforestation regulations”, setting out that businesses in Great Britain with an annual turnover of over £1 million that use forest risk commodities will have to establish a due-diligence system, report on their activity, and hold proof of compliance including geolocation data on product origin. The commodities named are wood, cattle, cocoa, coffee, palm oil, rubber and soy, plus certain derived products such as chocolate and furniture — deliberately close to the EU Deforestation Regulation.
A proposal, not an enacted threshold
The £1 million turnover figure, the seven-commodity list and the derived-product scope are the Government's stated intention as of June 2026, to be consulted on before regulations are made.
Do not treat any of them as the operative rule — they are not yet law.
The June 2026 plan supersedes a narrower 2023 proposal
An earlier plan set a much higher turnover threshold and a shorter commodity list. Treat it as history.
515 Defra consulted on implementing due diligence on forest risk commodities in 2021–22 (16,838 responses), and in a December 2023 written statementthe then-Government proposed a narrower regime: four commodities — cattle products (excluding dairy), cocoa, palm oil and soy — a £50 million global annual turnover threshold, and an exemption for businesses using 500 tonnes or less of each commodity a year. The June 2026 approach materially changes this — seven commodities and a much lower £1m threshold — so the 2023 figures should be treated as superseded.
EUDR applies directly in Northern Ireland
The four-nations picture splits again here: Great Britain builds its own regime while the EU rules reach Northern Ireland directly.
The EU Deforestation Regulation applies directly in Northern Ireland under the single-market-access arrangements, on the EU’s own (repeatedly revised) timetable, while Great Britain develops its own aligned but separate regime. The UK plan is designed to operate consistently alongside the EUDR — broadly the same information requirements — so a business trading across the UK internal market is not left facing two wholly different systems. For how UK sustainability and environmental duties split by nation more generally, see UK sustainability regimes by jurisdiction.
Is UK deforestation due diligence the law yet?
No.
The regime is a framework in Schedule 17 of the Environment Act 2021, which is enacted but does not impose any duty on its own.
The duties would only take effect once secondary legislation specifies the regulated commodities, thresholds and start date, and as of September 2026 no such regulations have been made.
The Government's own current plan expects implementing legislation in Great Britain in 2027.
Until then there is nothing to comply with under this regime.
What is the proposed GB Deforestation Regulation?
On 23 June 2026 the Government published “The UK's approach to deforestation regulations,” setting out that businesses in Great Britain with an annual turnover of over £1 million that use forest risk commodities will have to establish a due-diligence system, report on their activity, and hold proof of compliance including geolocation data on the origin of products.
The commodities named are wood, cattle, cocoa, coffee, palm oil, rubber and soy, plus certain derived products such as chocolate and furniture.
This is a proposal to be consulted on before regulations are made — not a rule in force.
Which businesses and commodities would be in scope?
Under the June 2026 plan, businesses in Great Britain with an annual turnover of over £1 million that use any of seven commodities — wood, cattle, cocoa, coffee, palm oil, rubber and soy — plus derived products.
Note that these figures are the Government's stated intention, not enacted thresholds; both the £1m turnover figure and the commodity list are subject to consultation and could change.
How does this differ from the earlier 2023 proposal?
It is materially wider.
A December 2023 written statement had proposed a narrower regime: four commodities — cattle products (excluding dairy), cocoa, palm oil and soy — a £50 million global annual turnover threshold, and an exemption for businesses using 500 tonnes or less of each commodity a year.
The June 2026 approach lowers the turnover threshold to £1 million and expands the list to seven commodities to align with the EU.
The 2023 figures should be treated as superseded, not as the current plan.
What about the EU Deforestation Regulation and Northern Ireland?
The EU Deforestation Regulation (EUDR) applies directly in Northern Ireland under the single-market-access arrangements, on the EU's own (repeatedly revised) timetable, while Great Britain develops its own aligned but separate regime.
The UK plan is deliberately designed to operate consistently alongside the EUDR, with broadly similar information requirements, so that a business trading across the UK internal market does not face two wholly different systems.
How does this relate to the EU rules businesses already face?
Businesses that place products on the EU market, or in Northern Ireland, may already be within scope of the EUDR regardless of the Great Britain timetable.
The forthcoming GB regime is intended to be broadly consistent with the EUDR, but it is a distinct legal instrument on its own schedule; a GB business is not automatically compliant with one by complying with the other.
Related guides & references
UK Sustainability Reporting by Sector
The directory of industry-specific reporting regimes, including the finance and supply-chain rules
UK Sustainability Regimes by Jurisdiction
Why Schedule 17 extends across all four nations while the GB and NI regimes diverge
Scope 3 Emissions
Where supply-chain due diligence and value-chain emissions reporting meet
SECR Compliance Guide
The size-based carbon reporting a commodities business is more likely to face today