UK Government to introduce Great Britain Deforestation Regulation
The UK Government has outlined its updated approach to tackling deforestation in supply chains, confirming plans to introduce a mandatory due diligence regime for forest risk commodities in Great Britain (GB).
While the regime remains subject to consultation, the announcement gives an indication on the proposed scope, timing and interaction with the EU Deforestation Regulation (EUDR) (see our earlier blog on EUDR here).
What has been announced?
On 23 June 2026, the Government set out its proposed approach (see here and here). The proposals signal a clear move towards mandatory due diligence obligations for businesses using high‑risk commodities in GB (note that in line with maintaining access to the EU single market, businesses in Northern Ireland will be subject to the EUDR).
Companies who use certain products that carry a higher risk of deforestation would need to undertake due diligence to ensure that products are produced in compliance with relevant local laws. Businesses will need to collect detailed supply chain information as part their due diligence, including geolocation data identifying the origin of products.
This marks a shift away from voluntary measures, with the Government emphasising that mandatory rules are necessary to address the UK’s contribution to global deforestation.
Who will be impacted?
The proposed regime is expected to apply to businesses in GB with annual turnover exceeding £1 million that use or place relevant commodities or derived products on the market.
The relatively low turnover threshold means that the regime will capture a broad set of UK businesses, not only large multinationals.
What products are caught?
The proposed scope covers the same key forest risk commodities as the EUDR:
- cattle,
- cocoa,
- coffee,
- palm oil,
- rubber,
- soy, and
- wood.
The GB regime will also extend to derived products, such as chocolate and furniture, where these contain or are made from these commodities. We anticipate the extent to which derived products are included will be a core aspect of future consultation.
How does this relate to the EUDR and what does it mean for businesses in Northern Ireland?
The UK has signalled a clear intention to ensure operational alignment with the EUDR, while maintaining a distinct domestic framework.
- the EUDR will apply in Northern Ireland from 30 December 2026 (phased); and
- in GB, the aim is to design a regime where due diligence requirements and data expectations are broadly consistent with the EUDR, enabling interoperability for businesses.
However, an important distinction remains: the UK regime intends initially to focus only on illegal deforestation (i.e. compliance with local laws), rather than the EUDR’s broader requirement that products be deforestation‑free.
The Government has though indicated that it may move towards a deforestation‑free standard over time.
Timing
The UK regime will be developed in stages:
- a consultation on detailed proposals is expected later in 2026; and
- legislation is expected in 2027.
Key takeaway
Although the detailed framework is still to come, the direction of travel is clear. Companies who are developing EUDR compliance programs should consider whether they may need to expand to programmes to also capture products destined for GB, particularly given the different thresholds that applies and the distinct approach in GB and Northern Ireland. Please get in touch with your usual Freshfields contact if you wish to discuss the announcement and preparing for future compliance.
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