UK deforestation law vs EUDR: how the two regimes differ

The EU Deforestation Regulation (Regulation (EU) 2023/1115) is a single, in-force EU law with fixed dates: 30 December 2026 for large and medium operators and traders, and 30 June 2027 for most micro and small operators. The UK's own deforestation law — the forest risk commodities regime under Schedule 17 of the Environment Act 2021 — is a different instrument, covers only Great Britain, is not yet in force, and currently targets only illegal deforestation rather than the EUDR's deforestation-free standard. The two are not interchangeable, and complying with one does not satisfy the other.

Businesses that trade commodities on both sides of the Channel keep asking which rules actually bind them and when. This page sets the two regimes side by side.

What is the EUDR, in one paragraph?

Regulation (EU) 2023/1115, as amended by Regulation (EU) 2025/2650, requires anyone who places cattle, cocoa, coffee, oil palm, rubber, soya, wood or specified derived products (including packaging and components) on the EU market, or exports them from it, to hold a due diligence statement proving the goods are deforestation-free — not produced on land deforested or degraded after 31 December 2020 — and legally produced. The statement is filed in the EU's TRACES system, referencing the plot or establishment the commodity came from. It applies throughout the EU and, via the Windsor Framework, in Northern Ireland. It does not apply directly to a business established only in Great Britain. See which EUDR application date applies to you for the size and product tests in full.

What is the UK's own deforestation law?

Schedule 17 of the Environment Act 2021 gives the Government power to make regulations requiring UK businesses to carry out due diligence on forest risk commodities, and to make it an offence to use a regulated commodity in commercial activity unless it was produced in compliance with the laws of the country of production. No regulations have yet been made under that power. There is, as of this run, no live operational due diligence obligation under UK domestic law — only the commercial pressure that flows from EU customers' own EUDR duties, covered in our guide for UK businesses selling into the EU.

In June 2026 the Government confirmed it will introduce mandatory due diligence requirements for businesses in Great Britain under this power, revising the original 2021–22 design to move closer to the EUDR. GOV.UK states the Government is aiming for this to cover "businesses in GB with an annual turnover of over £1 million, that use forest risk commodities and wood products." Implementing legislation is expected in 2027; no application date has been set.

How the two regimes actually differ

	EUDR (Regulation (EU) 2023/1115)	UK forest risk commodities regime (Schedule 17)
Status	In force; application dates running	Not in force; legislation expected 2027
Territory	EU, plus Northern Ireland	Great Britain only
Who is caught	Anyone placing in-scope products on the EU market or exporting them, regardless of size — size changes the deadline and documentation, not whether you're caught	Proposed: GB businesses with turnover over £1 million that use the commodities
Standard applied	Deforestation-free: not produced on land deforested or degraded after 31 December 2020	Proposed: compliance with the local law of the country of production — an illegal-deforestation test, not a deforestation-free one
Commodities	Cattle, cocoa, coffee, oil palm, rubber, soya, wood, plus Annex I derived products	Proposed: wood, cattle, cocoa, coffee, palm oil, rubber, soy, plus derived products such as chocolate and furniture
Filing mechanism	Due diligence statement filed in TRACES, with plot-level geolocation	Not yet designed; Government intends information requirements "broadly the same as" an EUDR due diligence statement
Deadlines	30 December 2026 (large/medium, and micro/small on timber-covered products); 30 June 2027 (other micro/small); 30 December 2027 (products added by Delegated Regulation (EU) 2026/2102)	None set

The gap that catches people out most is the standard, not the dates. The EUDR asks whether the land itself was deforested after a fixed cut-off, irrespective of whether that clearance was lawful where it happened. The proposed GB regime, as currently framed, asks only whether the commodity was produced in breach of the production country's own laws — so legal deforestation under a weak local regime could pass the GB test while failing the EUDR's. The Environmental Audit Committee has recommended Parliament widen Schedule 17 to cover all deforestation, not only illegal deforestation, and the Government has said it intends to "move towards a deforestation-free standard in due course" — but that is a stated future intention, not the current proposal.

Does being EUDR-compliant make you compliant with the UK regime too?

Not automatically, and not yet, because there is nothing to be compliant with: no GB secondary legislation is in force. Once it is, expect substantial overlap but not equivalence. The same plot-level geolocation and legality evidence you gather for an EUDR due diligence statement will very likely satisfy most of what a future GB regime asks for, since the Government has said it is aligning the information requirements. But the legal tests differ — deforestation-free versus legality-of-production — so a product that clears the lower GB bar is not guaranteed to clear the EUDR's, and the two obligations will sit as separate legal instruments even where their paperwork overlaps. Build your evidence file to the EUDR's higher standard and you are very likely covering the GB regime already; build it only to a legality test and you may not be covering the EUDR.

Does this affect a GB business that only sells domestically?

Potentially, once the GB regime is in force — that is the point of it. The EUDR only reaches a GB business commercially, through what EU customers demand (see the downstream obligations guide for how that split works). A GB business that uses forest risk commodities purely in domestic UK supply chains, with no EU sales at all, currently faces no deforestation due diligence duty of any kind. That will change for businesses over the proposed £1 million turnover threshold once Schedule 17 regulations are made — but there is no date for that yet, and nothing to comply with in the meantime.

Does the UK's low country-risk rating under EUDR help with the GB regime?

No, and the two aren't related. The EUDR's country benchmarking under Implementing Regulation (EU) 2025/1093 rates the United Kingdom as low risk as a country of production, which unlocks simplified due diligence for commodities genuinely grown or raised in the UK, under EUDR rules only. See how country benchmarking works for what that actually changes. It has no bearing on the design, threshold or standard of the UK's own forthcoming domestic regime, which is a separate piece of legislation entirely.

Why has the UK taken so much longer than the EU?

The two regimes started from roughly the same place and diverged sharply on speed. The UK Government ran its first consultation on forest risk commodity due diligence in 2020, received more than 16,000 responses, and took the power to legislate in Schedule 17 of the Environment Act 2021 — before the EU had even finalised the EUDR text. Regulation (EU) 2023/1115 then moved from proposal to law in roughly two years, with fixed dates written into it from the start.

The UK power has sat unused since 2021. A 2024 report from Parliament's Environmental Audit Committee criticised the delay and recommended the Government widen the eventual scope to cover all deforestation, not only illegal deforestation, and extend the commodity list to include products such as coffee and rubber that the original 2020–21 proposals had treated inconsistently. The Government's June 2026 announcement responded to some of this — most visibly by lowering the proposed turnover threshold and folding wood products back in — but the core design, an illegality test rather than a deforestation-free one, is unchanged from what the Committee criticised. Secondary legislation is now targeted for 2027, six years after the Act that enables it.

What happens if your business falls under both regimes eventually?

For a business that both sells into the EU or Northern Ireland and trades forest risk commodities domestically in Great Britain above the proposed £1 million threshold, the realistic outcome once both regimes are operative is two separate compliance records drawing on mostly the same underlying evidence. You will still need a TRACES-filed due diligence statement for anything you place on the EU market or move to Northern Ireland, built to the deforestation-free standard. You will separately need to satisfy whatever the GB regulations require once made, on their own test and their own timetable. Running one evidence-gathering process — plot-level geolocation, supplier legality documentation, retained for the longer of the two regimes' record-keeping periods — and mapping it against both sets of requirements is more efficient than treating them as two separate projects, but it does not make them one obligation in law.

What should a business actually do now?

1. Keep complying with the EUDR on its own timetable if it binds you — directly, or commercially through an EU customer. That obligation is real and running now.
2. Do not build a GB compliance programme around Schedule 17 yet. There is no in-force duty, no commodity list in law, no threshold in law, and no application date.
3. If you already hold EUDR-standard geolocation and legality evidence, keep it. It is very likely to cover most of what the GB regime eventually asks for, given the Government's stated intention to align the two.
4. Watch for the GB regulations, expected in 2027, particularly the final commodity list, the £1 million threshold, and whether the test stays illegal-deforestation-only or moves to deforestation-free before it is made law.
5. Treat the two as separate obligations in your compliance records, even after the GB regime takes effect. A due diligence statement that satisfies the EUDR is not, in law, a filing against Schedule 17, and vice versa.

Check where the EUDR actually puts you

The GB regime is not yet operative, but the EUDR is, on a fixed and approaching timetable. If you have not worked out your role, deadline and obligations under the regulation that is actually in force, that is the more urgent gap.

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