UK consults on deforestation checks for food commodities

The Department for Environment, Food & Rural Affairs has opened a consultation on mandatory due diligence for businesses using commodities associated with illegal deforestation in Great Britain. Published on 11 November, the proposals cover supply chains involving materials such as cocoa, coffee, palm oil, soy and cattle products, alongside timber and rubber. They would extend the government’s approach to checking whether commodities used in commercial activity have been produced in accordance with relevant laws in their country of origin. Responses are requested by 17 January 2027; the details remain proposals rather than obligations already in force.

The consultation considers which businesses and products should fall within the rules, how a due diligence system should operate and how companies should identify, assess and mitigate illegal deforestation risks. The government’s stated approach is to cover businesses with annual turnover above £1 million, with the precise legal scope subject to the consultation. It also seeks evidence on implementation costs and the effects of the regime. The policy is framed as a legality-based system, which is an important distinction from a blanket prohibition on every commodity originating in an area where forests have been lost. The precise product scope, exemptions, administrative requirements and enforcement arrangements have not yet been finalised.

Several proposed commodities are fundamental to industrial food production. Cocoa enters chocolate and confectionery manufacture in multiple forms, including liquor, butter and powder. Palm-derived oils and fractions are used in bakery, confectionery and processed-food formulations. Soy can be an ingredient in its own right or enter animal feed supply chains, while coffee passes through roasting, grinding, extraction and packing operations. The range of products and intermediate traders between origin and finished food means manufacturers may rely on evidence assembled across several tiers of procurement rather than by a single direct supplier.

A company buying a finished ingredient can face a more complicated traceability challenge than an importer purchasing a recognisable raw commodity. Materials from different farms or processing sites may be blended or transformed before they reach a UK manufacturing plant, and commercial invoices alone do not necessarily establish compliance at origin. The policy paper anticipates geolocation information identifying the origin of commodities, alongside risk assessment and evidence that applicable local laws have been followed. The consultation is intended to clarify what evidence businesses should collect and which actors are expected to carry the legal responsibility.

The government plans to use powers including those under the Environment Act 2021, alongside changes strengthening existing timber rules. Its policy paper indicates that implementing legislation for Great Britain is expected in 2027. Its stated objective is a workable framework that reduces illegal deforestation without introducing avoidable conflict with other regulatory systems. That issue is particularly significant for manufacturers with supply chains serving both Great Britain and the European Union. Systems built around commodity origin, supplier declarations, verification records and product identity can become costly if the same consignment must be documented in materially different ways for different markets.

Northern Ireland has a separate timetable under the EU Regulation on Deforestation-free Products. Government material accompanying the announcement says that regime will begin to apply there in phases from 30 December 2026. Great Britain’s proposal is therefore at a different point in the legislative process from the arrangements affecting Northern Ireland. The proposals aim to reduce differences in evidence requirements across the UK internal market, including for businesses moving ingredients or finished goods between Great Britain and Northern Ireland. It would be premature to describe the two systems as already aligned or to assume identical reporting obligations.

Defra’s approach follows wider international efforts to associate commodity procurement with environmental legality. A legality-based check generally asks whether relevant national laws have been followed, whereas a deforestation-free standard can impose an additional environmental condition irrespective of local legality. The government has described a longer-term ambition to move towards deforestation-free supply chains, but the current consultation is concerned with designing a due diligence framework and obtaining evidence about its likely burden. The precise legal test for each commodity will depend on the regulations eventually introduced.

Ingredient manufacturers and food processors will have practical questions about traceability systems, document retention, audits and how different material forms should be handled. The risk assessment process may require procurement teams to work more closely with technical, quality and legal colleagues when new suppliers are approved or existing sourcing routes change. Smaller businesses could encounter different compliance costs and information gaps from multinational producers with established supplier verification programmes. Defra is seeking evidence on costs and risks before finalising the design, including which businesses and products will be captured. The proposed £1 million turnover threshold should not be treated as an enacted exemption.

The government’s announcement coincided with international forest-policy discussions at COP31 in Antalya, but the next domestic milestone is the consultation deadline in January. Defra will consider responses received by 17 January 2027 before deciding how to proceed. The final rules will determine which ingredient flows require new supplier evidence, geolocation records and risk assessments, and how those obligations align with the separate EU regime in Northern Ireland.