Forest risk commodities · status at 1 October 2026
UK deforestation due diligence: what is in force, and what is not
UK deforestation due diligence for forest risk commodities is not yet a legal duty: Schedule 17 of the Environment Act 2021 is in force only so that regulations can be made, and none has been.
Defra’s June 2026 plan proposes a Great Britain regime, with legislation expected in 2027.
Two rules do bite: timber due diligence has applied across the UK since 2013, and the EU Deforestation Regulation applies in Northern Ireland from 30 December 2026.
Status ledger
In force, partly in force, proposed, superseded
Every rule a UK business hears about under “deforestation due diligence”, with its status on 1 October 2026 and the document that sets it.
| Rule | Status | Who it reaches | Source |
|---|---|---|---|
| UK Timber Regulation | In force | Timber and timber products, across the UK since 2013 | SI 2013/233 |
| Environment Act 2021 s.116 and Schedule 17 | In force only to make regulations | Nobody yet: since 30 September 2022 the provisions exist so that regulations can be made | SI 2022/518 reg 3(c)–(d) |
| Regulations under Schedule 17 | None made | Would specify commodities, regulated persons, thresholds and start dates | Sch 17 |
| Great Britain deforestation regime | Proposed | GB businesses with turnover over £1 million using forest risk commodities and wood products | Defra, 23 June 2026 |
| The December 2023 proposal | Superseded | Was: four commodities, £50 million global turnover, 500-tonne exemption | HCWS117 |
| EU Deforestation Regulation | Applies from 30 December 2026 | Operators placing relevant goods in Northern Ireland or the EU; micro and small from 30 June 2027 | Reg (EU) 2023/1115 Art 38 |
Commencement
Schedule 17 is in force — for one purpose only
Part 6 of the Environment Act 2021 did not come into force on Royal Assent: section 147(3) brings it in by regulations.
The Commencement No. 3 Regulations brought section 116 and Schedule 17 into force on 30 September 2022 “for the purpose of making regulations”, and for no other purpose.
That lets the Secretary of State make the regulations that would switch the duties on; it does not switch them on.
The duties bite only when regulations specify the commodities, the regulated persons and the start date, and none has been made.
Schedule 17 extends to England and Wales, Scotland and Northern Ireland under section 146(6)(b), but extent is not commencement, and Defra now plans a Great Britain regime with the EU rules applying in Northern Ireland.
“Schedule 17 has not been commenced.”
“Schedule 17 is in force.”
It was commenced on 30 September 2022 for the purpose of making regulations.
No regulations exist, so no business duty has started.
What the framework says
Schedule 17 is a legality test
| Paragraph | What it provides |
|---|---|
| ¶1(4) | “Forest” means land of more than 0.5 hectares with tree canopy cover of at least 10%, excluding trees planted to produce timber or other commodities. |
| ¶1(6) | The regulations may not specify timber or timber products within the meaning of the EU Timber Regulation. |
| ¶2(1) | A regulated person must not use a forest risk commodity in its UK commercial activities unless relevant local laws were complied with in relation to it. |
| ¶3(2) | A due diligence system identifies and obtains information about the commodity, assesses the risk that local laws were not complied with, and mitigates that risk. |
| ¶4(2), ¶4(6) | An annual report no later than 6 months after a reporting period; the first period ends with the 31 March after the paragraph comes fully into force, then 12-month periods. |
| ¶5(1)–(3) | An exemption, on notice, where use will not exceed a prescribed threshold. |
| ¶7(1) | A regulated person carries on commercial activities in the UK and meets turnover conditions set in regulations, or is a subsidiary of one that does. |
Illegal, not all, deforestation
The test in ¶2(1) is whether relevant local laws were complied with, so the framework targets illegal deforestation.
Defra says that in due course it intends to move towards a deforestation-free standard.
The EU’s own rule, which already requires deforestation-free goods and reaches UK businesses that supply the EU, is on EUDR.
Where wood fits
¶1(6) keeps timber within the EU Timber Regulation’s meaning out of Schedule 17.
Defra’s plan covers wood products “alongside legislation that will strengthen the UK Timber Regulation”; the detail is for its consultation.
The June 2026 plan
A Great Britain regime, proposed for 2027
On 23 June 2026 Defra published The UK’s approach to deforestation regulations.
It aims to require businesses in Great Britain with annual turnover over £1 million, that use forest risk commodities and wood products, to carry out due diligence that they were produced in compliance with relevant local laws.
The commodities named are wood, cattle, cocoa, coffee, palm oil, rubber and soy, plus derived products such as chocolate and furniture.
An in-scope business would establish a due diligence system, report on its activity, and hold proof of compliance by collecting geolocation data on where products come from.
Every element is subject to consultation: the government’s announcement said it would consult later in 2026, and the plan expects legislation for Great Britain in 2027.
The £1 million figure and the commodity list are the government’s stated intention, not an enacted threshold.
- 2021–22First Defra consultation
16,838 responses.
- 12 Dec 2023Narrower plan (HCWS117)
Now superseded.
- 23 Jun 2026The UK’s approach published
Seven commodities; turnover over £1m.
- Later in 2026Consultation promised
On the Great Britain policy.
- 2027Legislation expected
No business start date set.
History
The 2023 proposal, and why it is history
Defra consulted on due diligence for forest risk commodities in 2021–22 and received 16,838 responses.
In a written statement of 12 December 2023 the then government proposed a narrower regime: cattle products excluding dairy, cocoa, palm oil and soy; a global annual turnover threshold of £50 million; and an exemption for businesses using 500 tonnes or less of each commodity a year.
The June 2026 plan replaces all three numbers: seven commodities, wood and coffee and rubber among them, and a threshold of £1 million.
Guidance or contracts written against the £50 million test are describing a proposal that no longer exists.
Your position
What applies to your goods today?
The answer turns on three facts: where the goods go, what they are, and how big the operator is.
Goods used only in Great Britain meet the UK Timber Regulation if they are timber, and nothing else yet.
Goods placed on the Northern Ireland or EU market meet the EU Deforestation Regulation on its own dates.
The checker sets out each rule with its status and source; who counts as an operator or a downstream operator under the EU rules is a test of its own.
Status check · what applies today
Great Britain: no forest-risk-commodity duty yet.
Defra aims to require businesses with annual turnover over £1 million to carry out due diligence, after consultation; legislation is expected in 2027.
Source: Environment Act 2021 Sch 17; SI 2022/518 reg 3; Defra, 23 June 2026
Status as at 1 October 2026.
Who counts as an operator, trader or downstream operator under the EUDR is its own test.
Nothing you tick is stored or sent.
Northern Ireland and exports
The EU Deforestation Regulation in the UK
The government has confirmed that the EUDR applies in Northern Ireland, as part of the arrangements that keep its access to the EU single market.
Its dates have moved twice; Regulation (EU) 2025/2650 set the ones in force, in Article 38: large and medium operators from 30 December 2026, micro and small operators from 30 June 2027.
Defra’s guidance adds that micro and small operators follow the rules from 30 December 2026 for wood products already regulated under the EU Timber Regulation.
The 2025 amendment also changed who files: downstream operators and traders collect and keep the reference from the first operator in the chain rather than submit their own due diligence statement.
The UK is classed as a low-risk country, so operators can use simplified due diligence for goods produced in Great Britain and exported to the EU or moved to Northern Ireland.
How this and other rules divide between Great Britain and Northern Ireland is set out on UK sustainability regimes by jurisdiction.
| Competent authority (NI) | Commodities |
|---|---|
| Office for Product Safety and Standards | Rubber and wood products |
| DAERA | Palm oil, soy, cocoa, cattle and coffee |
Reporting
Where commodity risk shows up in reporting now
Until Great Britain regulations are made, the reports a business already files are where commodity exposure appears.
Emissions in purchased commodities sit in a company’s Scope 3 emissions.
For listed companies the FCA’s UK SRS rules bring Scope 3 in on a comply-or-explain basis after a one-year relief; for everyone else it is voluntary.
SECR covers energy and Scope 1 and 2 emissions, not supply-chain deforestation.
Due diligence obligations of this kind are one of several sector-specific regimes collected on UK sustainability reporting by sector.
A business preparing now can map which of its products contain the seven commodities and where they come from, since geolocation is common to the Great Britain plan and the EU rules.
Frequently asked
Deforestation due diligence, answered
Is UK deforestation due diligence the law yet?
Not for forest risk commodities.
Schedule 17 of the Environment Act 2021 has been in force since 30 September 2022 only for the purpose of making regulations, and no regulations have been made, so no business has a duty under it.
Timber is different: the UK Timber Regulation has required due diligence across the UK since 2013.
What is the proposed GB deforestation regulation?
Defra’s plan of 23 June 2026 is to require businesses in Great Britain with annual turnover over £1 million that use forest risk commodities and wood products to carry out due diligence that they were produced in compliance with relevant local laws, to report, and to hold proof including geolocation data. It is subject to consultation, and legislation is expected in 2027.
Which commodities would be covered?
Defra names wood, cattle, cocoa, coffee, palm oil, rubber and soy, and certain derived products such as chocolate and furniture — the same core commodities as the EU Deforestation Regulation.
The list is part of the proposal and subject to consultation.
When will the UK deforestation rules come in?
Defra expects legislation to implement the Great Britain regime to be delivered in 2027, after a consultation it said in June 2026 would come later that year.
No start date for business obligations has been set.
Is palm oil illegal in the UK?
No. Neither palm oil nor any other forest risk commodity is banned.
Schedule 17 would, once regulations are made, prohibit larger businesses from using a commodity unless relevant local laws were complied with in producing it — a legality test, not a ban on the commodity.
Is the EUDR delayed to 2026?
Yes, twice.
Regulation (EU) 2025/2650 set the dates now in force: large and medium operators from 30 December 2026, micro and small operators from 30 June 2027.
Sources still citing 30 December 2025 are one postponement behind.
Does the EU Deforestation Regulation apply in the UK?
In Northern Ireland, yes: the government has confirmed the EUDR applies there in phases from 30 December 2026, as part of Northern Ireland’s access to the EU single market.
In Great Britain it applies only to businesses placing relevant goods on the EU or Northern Ireland market.
How does the June 2026 plan differ from the 2023 proposal?
The December 2023 written statement proposed four commodities (cattle products excluding dairy, cocoa, palm oil and soy), a £50 million global turnover threshold and an exemption for using 500 tonnes or less of each commodity a year.
The June 2026 plan has seven commodities including wood and a £1 million threshold.
The 2023 figures are superseded.
Is the UK regime a deforestation-free standard?
Not as planned.
Schedule 17 tests whether relevant local laws were complied with, so it targets illegal deforestation.
Defra says that in due course it intends to move towards a deforestation-free standard.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukEnvironment Act 2021, Schedule 17 (Use of forest risk commodities in commercial activity)
The framework: forest definition, timber carve-out, prohibition, due diligence, reports, exemptions, regulated persons (¶¶1–7).
- legislation.gov.ukEnvironment Act 2021, section 116
The section that introduces Schedule 17, and its commencement annotations.
- legislation.gov.ukEnvironment Act 2021, section 146(6)
Section 116 and Schedule 17 extend to the whole UK.
- legislation.gov.ukEnvironment Act 2021, section 147(3)
Part 6 comes into force by regulations, not on Royal Assent.
- legislation.gov.ukThe Environment Act 2021 (Commencement No. 3) Regulations 2022, SI 2022/518, regulation 3
Section 116 and Schedule 17 in force on 30 September 2022, “for the purpose of making regulations”.
- GOV.UK (Defra)The UK’s approach to deforestation regulations (23 June 2026)
The Great Britain proposal, the UK Timber Regulation since 2013, the EUDR in Northern Ireland and its dates.
- GOV.UK (Defra)Government steps up action to tackle illegal deforestation (23 June 2026)
Consultation “later this year”; the EUDR in Northern Ireland in phases from 30 December 2026.
- UK ParliamentWritten statement HCWS117, Forest Risk Commodities (12 December 2023)
The earlier, superseded proposal: four commodities and a £50 million threshold.
- legislation.gov.ukThe Timber and Timber Products (Placing on the Market) Regulations 2013, SI 2013/233
The UK Timber Regulation, in force.
- EUR-LexRegulation (EU) 2023/1115, consolidated text, Article 38
The EUDR application dates: 30 December 2026 and 30 June 2027.
- EUR-LexRegulation (EU) 2025/2650
The second postponement, and the new downstream-operator and micro or small primary operator rules.
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