New measures build on existing regulation to bring the UK further in line with the EU.
By Michael D. Green and James Bee
On 23 June 2026, the UK government announced plans for new rules intended to ensure that goods sold in the UK do not contribute to illegal deforestation. The measures will cover Great Britain, while businesses in Northern Ireland will be subject to the EU Deforestation Regulation (EUDR) to maintain access to the EU single market.
Current UK Approach to Deforestation
Since 2013, the UK Timber Regulations (UKTR) has established obligations for businesses trading in timber and timber-related products and aimed to prevent trade in illegally harvested timber. Operators who place timber on the UK market must exercise due diligence and maintain a due diligence system that is regularly evaluated. The government intends for the new measures to strengthen the UKTR, although details on exactly what this will entail remain to be seen.
The government has announced that it aims to introduce regulations under the Environment Act 2021, alongside legislation that will strengthen the UKTR. The regulations under the Environment Act will prevent businesses from using illegally produced forest-risk commodities through the establishment of due diligence systems and corresponding reporting requirements.
Under the proposed legislation, the measures will apply to seven core commodities (cattle, cocoa, coffee, palm oil, rubber, soy, and wood) and certain derived products. They will apply to businesses in Great Britain with annual turnover exceeding £1 million that use or place these commodities on the market. The policy will require in-scope businesses to ensure that commodities are produced in compliance with relevant local laws (i.e. that they do not represent illegal deforestation).
Comparison With the EUDR
The EU already has in place regulation intended to ensure products placed on the EU market are deforestation-free, under the EUDR, with obligations applying to most operators and traders from 31 December 2026.
The UK government has stated that it intends to ensure these measures “operate consistently” alongside the EUDR, so that businesses will hold broadly the same information as required for due diligence statements when exporting to the EU. Further, because the EUDR will apply in Northern Ireland from the end of the year, a level of consistency across Great Britain and Northern Ireland is needed to ensure that the dual market access upon which businesses in Northern Ireland depend is maintained.
The UK Government’s proposed deforestation requirements are intended to apply to the same seven core commodities as under the EUDR, although there is potential for variation in relation to the scope of the derived products. The EU has recently published a draft delegated act that amends the range of products and commodities falling within scope of the EUDR (see this Latham blog post). The list of derived products for the UK measures is likely to feature in the upcoming consultation.
While the proposed rules ensure greater alignment with the EU position, the EU and UK approaches differ in several aspects:
- When the EUDR was adopted in 2023, it replaced the EU Timber Regulation. This approach differs from the UK government’s measures, which will retain but strengthen the UKTR.
- There is no revenue threshold for the EUDR; it applies to all entities placing relevant goods on the EU market (although smaller entities may be subject to certain implementation delays and differing obligations).
- The UK regime intends to tackle illegal deforestation, whereas the EUDR requires products to comply with local laws and also be deforestation-free (defined as commodities not from land subject to deforestation after 31 December 2020). Reports indicate that the UK government’s future ambition is to move to a deforestation-free standard “in due course”, but no timeline has been indicated.
Timeline and Next Steps
The government announcement indicates that legislation to implement the regime should be delivered in 2027, following a consultation process in 2026. Further details on the consultation are expected to be announced shortly. In the meantime, the UK government is also working on further specific guidance on movement of goods from Great Britain to Northern Ireland as a priority.
This article was prepared with the assistance of Samantha Banfield and James Thompson at Latham & Watkins.
Latham & Watkins will continue to monitor developments relating to the UK’s deforestation measures and the broader European sustainability regulatory landscape.