Introduction

On June 23, 2026, the UK government announced plans to introduce the UK Forest Risk Commodity Regulation, a mandatory due diligence regime requiring businesses in Great Britain to verify that forest risk commodities in their supply chains are not linked to illegal deforestation. The regulation will use powers under the Environment Act 2021 alongside a strengthened UK Timber Regulation, and will apply to businesses with an annual turnover over £1 million that use commodities such as soy, palm oil, cocoa, rubber, cattle, and coffee. Unlike the EU Deforestation Regulation, which requires products to be deforestation free, the UK regime will initially require only that commodities comply with the local laws of the country where they were produced.

Key Takeaways

• The UK Forest Risk Commodity Regulation was announced on June 23, 2026, and will require GB businesses with turnover over £1 million to conduct supply chain due diligence on named forest risk commodities.
• The regulation targets illegal deforestation only, based on compliance with local laws, which is a narrower standard than the EU Deforestation Regulation’s deforestation free requirement.
• Northern Ireland will follow the EU Deforestation Regulation directly, applying in phases from December 30, 2026, to preserve its dual market access to the UK and EU.
• A public consultation on the detailed UK policy is expected later in 2026, with legislation expected to be delivered in 2027.
• The Office for Product Safety and Standards and Northern Ireland’s Department of Agriculture, Environment and Rural Affairs have been designated as competent authorities for enforcing the EU Deforestation Regulation in the UK, covering rubber and wood, and palm oil, soy, cocoa, cattle, and coffee, respectively. A separate enforcement authority for the UK’s own Forest Risk Commodity Regulation in Great Britain has not yet been confirmed.

What Is the UK Forest Risk Commodity Regulation (UKFRC)?

The UK Forest Risk Commodity Regulation is the government’s proposed mandatory due diligence regime for businesses that use commodities associated with rainforest destruction. The UK government has stated that businesses in Great Britain who trade in commodities such as soy, palm oil, cocoa, and rubber will need to check that their supply chains are not contributing to illegal deforestation. The policy was announced during London Climate Action Week and builds on the existing Environment Act 2021 framework together with a strengthened UK Timber Regulation.

Legal Basis: The Environment Act 2021 and the UK Timber Regulation

The regulation’s legal foundation is not new. In 2021, the government stated that provisions under the Environment Act would introduce a due diligence requirement on forest risk commodities, following consultations held in 2020 and 2021. That earlier effort stalled, and the legislation was not brought into force before Parliament was dissolved ahead of the last general election. The June 2026 announcement restarts this process and pairs it with reforms to the UK Timber Regulation, which has applied a mandatory due diligence framework to timber since 2013.

Which Businesses Fall Within Scope? The £1 Million Turnover Threshold

The government aims to require businesses in Great Britain with an annual turnover of over £1 million, that use forest risk commodities and wood products, to carry out due diligence to ensure these are produced in compliance with relevant local laws. This threshold is intentionally broad, reaching well beyond the largest multinational importers into the mid-market businesses that make up a significant share of the UK’s food, retail, and consumer goods sectors. One detail still to be confirmed is the treatment of smaller volume users. The original 2020 to 2021 proposal included an annual volume exemption for businesses using less than 500 tonnes of a relevant commodity, and it is not yet clear whether this exemption will be carried into the current proposal. This is expected to be addressed in the upcoming consultation.

Covered Commodities and Derived Products

The government’s official materials name soy, palm oil, cocoa, and rubber as the forest risk commodities in scope, and the government’s own allocation of enforcement responsibilities between competent authorities confirms that cattle and coffee are also covered, alongside wood products brought in through the parallel strengthening of the UK Timber Regulation. The government has also confirmed that the regulation will extend to derived products, such as chocolate and furniture, where these are made from or contain the underlying commodities. This full list, soy, palm oil, cocoa, rubber, cattle, coffee, and wood, is the same set of commodities covered under the EU Deforestation Regulation, reflecting the government’s stated intention to keep the scope and information requirements of the GB regime broadly consistent with the EU regulation. What remains to be confirmed through consultation is how derived and embedded products, such as animal feed containing soy or palm oil, will be treated.

How Does the UKFRC Differ from the EU Deforestation Regulation (EUDR)?

The most significant distinction between the two regimes is the compliance standard itself. The UK regime is designed, at least initially, to address illegal deforestation only, meaning compliance with local laws in the country of production. The EU Deforestation Regulation sets a higher bar, requiring that products be deforestation free regardless of whether the clearing was legal under local law. In practice, this means a product grown on legally cleared land could satisfy the UK’s initial standard while still falling short of the EU standard. The UK government has indicated a longer-term ambition to move toward a deforestation free standard, though this is not part of the initial proposal.

UKFRC vs. EUDR at a Glance: Scope, Standard, and Enforcement Compared

Despite the differing standards, the two regimes are intended to operate consistently with one another. The UK government has stated that GB due diligence requirements are intended to require businesses to hold information similar to what is required under the EU Deforestation Regulation, in order to avoid duplicating compliance burdens for companies trading across both markets.

What Happens in Northern Ireland? EUDR Application and the December 30, 2026 Deadline

To preserve Northern Ireland’s dual access to the UK internal market and the EU single market, the EU Deforestation Regulation itself, rather than the UK’s domestic regime, will apply there in phases starting December 30, 2026. The government has designed the GB regime’s scope and information requirements to stay broadly aligned with the EU Deforestation Regulation, reducing divergence between Great Britain and Northern Ireland. The UK is also classified as a low-risk country under the EU Deforestation Regulation’s country risk system, allowing simplified due diligence for UK-produced goods exported to the EU or moved to Northern Ireland. For enforcement of the EU Deforestation Regulation in this context, the government has designated the Office for Product Safety and Standards as the competent authority for rubber and wood products, and Northern Ireland’s Department of Agriculture, Environment and Rural Affairs as the competent authority for palm oil, soy, cocoa, cattle, and coffee. A separate authority for the UK’s own Forest Risk Commodity Regulation in Great Britain has not yet been announced.

When Will the UKFRC Take Effect and What Should Businesses Do Now?

There is no confirmed enforcement date for the UK Forest Risk Commodity Regulation. The government has stated that it will consult businesses, civil society, and international partners later in 2026 on the details of the proposed policy, and that legislation to implement the regime in Great Britain is expected to be delivered in 2027. This places the current period in a pre-legislative window, where the exact treatment of derived and embedded commodities, any volume-based exemptions, and the enforcement timeline remain open questions to be shaped by the consultation.

Preparing for Due Diligence: Building Supply Chain Traceability Ahead of Legislation

Although the legislation is not yet final, the direction of the policy is clear enough for businesses to begin preparing. In-scope businesses will eventually need to establish a due diligence system, report on their activity, and hold geolocation data about the origin of relevant products, requirements that closely mirror what is already expected under an EU Deforestation Regulation due diligence statement. Businesses that trade soy, palm oil, cocoa, rubber, cattle, coffee, or wood products, or that manufacture derived goods such as chocolate or furniture, can use this period to map their exposure to these commodities and begin requesting origin and legality documentation from suppliers.

Conclusion

The UK Forest Risk Commodity Regulation signals that Great Britain is moving toward a mandatory, EUDR-adjacent due diligence regime, even as it retains a narrower legality-only standard for now. For businesses trading across Great Britain, Northern Ireland, and the EU, the practical effect is a converging set of data expectations: supplier-level origin evidence, legality documentation, and geolocation data, well before any single enforcement date arrives. Executive teams overseeing sourcing and sustainability strategy should treat this pre-legislative window as the time to begin mapping forest risk commodity exposure and building supplier data collection processes. ASUENE’s supply chain and Scope 3 data collection capabilities can help organizations start this work now, ahead of the UK consultation and the 2027 legislative timeline.

Why Work with ASUENE Inc.?

ASUENE is a key player in carbon accounting, offering a comprehensive platform that measures, reduces, and reports emissions, including Scope 1-3. ASUENE serves over 50,000 clients worldwide, providing an all-in-one solution that integrates GHG accounting, ESG supply chain management, a Carbon Credit exchange platform, and third-party verification.

ASUENE supports companies in achieving net-zero goals through advanced technology, consulting services, and an extensive network.