UK confirms deforestation due diligence
This London Climate Action Week, the government has confirmed its intention to introduce mandatory due diligence on tackling illegal deforestation in supply chains.
techUK welcomes the UK government’s announcement to finally bring forward its own deforestation regulation which is explicitly aligned with the EU, as this will bring greater certainty for businesses and benefit our members. We also eagerly await further confirmation as to whether the consultation will include details around mandatory human rights due diligence.
Where has this come from?
Let’s back up. In 2021, the UK passed the Environment Act, which includes a provision for government to establish a due diligence system for ‘forest-risk’ commodities via secondary legislation, the proposed Forest-risk Commodities Regulation (FRC). This followed a 2020 consultation, and was subsequently followed by a 2022 ‘implementation’ consultation.
However, at the same time the EU was busy designing its own EU Deforestation Regulation (EUDR), adopted in 2023, alongside its Corporate Sustainability and Reporting Directive (CSRD) and Corporate Sustainability and Due Diligence Directive (CSDDD). Initially intended to come into force in 2024/2025, the EUDR faced backlash from businesses and both European and third countries around salient issues such as compliance burden, competitiveness and trade barriers. As such, the EU eventually revised and delayed the implementation until 2026/2027.
Meanwhile, contending with political shifts, the UK effectively shelved its plans to introduce the FCR, as well as broader mandatory due diligence (i.e. for human rights). This delay, alongside the lack of alignment between EUDR and proposed FRC in terms of commodities covered, business scope, or enforcement mechanisms, has created significant uncertainty and burdens for businesses over the past few years.
What has been announced?
Later this year (2026), there will be a consultation on the substance of a new ‘GB deforestation policy’ under the Environment Act (2021). The regulations will come alongside legislation which will serve to strength the existing UK Timber Regulation. It is expected that legislation will be delivered in 2027.
Under the new deforestation regulations, businesses which trade certain commodities – wood, cattle, cocoa, coffee, palm oil, rubber, soy, and certain derived products like chocolate and furniture – will be required to ensure that these products do not come from illegally deforested locations (with a move to any deforestation in future).
In terms of scope, they have noted that businesses with an annual turnover of over £1 million that use the relevant risk commodities will be required to carry out due diligence to ensure these are produced in compliance with relevant local laws.
The government has framed the announcement around ensuring alignment with requirements affecting Northern Ireland; the rules in NI are determined by its border with Ireland, which is of course in the EU. Their aim is to ensure that the underlying information requirements for GB businesses will be aligned to what is needed for a due diligence statement when trading with the EU (and by extension, NI).
Why does this matter to tech?
While the tech sector may not seem like a primary sourcer of the in-scope commodities compared to other industries, certain materials (particularly wood and rubber) are widely used in the design of tech products, digital devices and infrastructure; therefore, many tech businesses will need to assess whether they (or aspects of their value chains) will be in scope.
On the other hand, tech and software is increasingly important for enabling better, easier compliance with supply chain due diligence – i.e. supply chain mapping platforms, automating risk assessments and reporting, and traceability and georeferencing.
Next steps
The government has recommended companies read about the implementation and guidance on compliance (including an overview of how obligations apply) with the EUDR, given the UK rules will be following a similar route.
techUK will be responding to the upcoming consultation when it is published. In the meantime, we will hold a session for members to learn more about how this will impact them.
Please get in touch with any questions!
Craig Melson
Craig is Associate Director for Climate, Environment and Sustainability and leads on our work in these areas ranging from climate change, ESG disclosures and due diligence, through to circular economy, business and human rights, conflict minerals and post-Brexit regulation.
Josh Turpin
Josh joined techUK as a Programme Manager for Telecoms and Net Zero in August 2024.
Elisabeth Sullivan
Elisabeth joined techUK in November 2025 as Sustainability Policy Manager within the Climate, Environment and Sustainability team.
Lucas Banach
Lucas Banach is Programme Assistant at techUK, he works on a range of programmes including Data Centres; Climate, Environment & Sustainability; Market Access and Smart Infrastructure and Systems.
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