Last updated: 21 November 2025
Overview
In November 2020, the Department for Environment, Food & Rural Affairs (DEFRA) introduced the Forest Risk Commodities (FRC) due diligence regime under the Environment Act 2021, aimed at tackling deforestation associated with products sold in the UK.
In December 2023, the former government announced further details and set out the scope of the planned implementing legislation. This followed a consultation, which concluded in March 2022, seeking views on the detailed implementing legislation required to establish which commodities and businesses fall within scope, what the due diligence obligations should entail, and how the requirements should be enforced. The current Labour government has affirmed its commitment to the FRC regime, but has yet to publish any implementing legislation to operationalise the regime.
What are the key takeaways?
- Once the implementing legislation is adopted, the FRC regime will make it illegal for businesses operating in the UK that meet the threshold requirements to use key forest risk commodities produced on land that is illegally occupied or used.
- The legislation will apply to businesses operating in the UK that have a global annual turnover of over GBP 50 million and use over 500 tonnes of key forest risk commodities per year.
- Key forest risk commodities will include cattle products (beef and leather), cocoa, palm oil and soy. Illegally logged timber is not included, as it is already controlled under a separate regime.
- In-scope businesses will be required to undertake a due diligence exercise on their supply chains and publish an annual report on this exercise.
- In terms of enforcement and penalties, fines and other civil sanctions will be issued for non-compliance.
What does this mean for your business?
Although the implementing legislation is yet to be seen, in-scope businesses can expect to undertake increased due diligence and supply chain evaluations in the future if they wish to place relevant products on the UK market. The FRC regime forms part of a wider trend of laws and regulations in both the EU and the UK, requiring businesses to take greater responsibility for the impact of their extended supply or value chains on human rights and the environment (including the EU Deforestation Regulation).
Next steps
The requirements of the FRC regime under the Environment Act 2021 will need to be specified in implementing legislation, which will govern how the FRC regime works in practice. However, this implementing legislation is yet to be published. In the Environment Plan 2023, the former government committed to introducing secondary legislation at the “earliest opportunity”. While the implementing legislation was expected to be laid out by the end of May 2024, it was delayed in light of the UK’s general election. In July 2025, the current government reaffirmed its commitment to protecting forests and confirmed that the government is considering its approach to addressing the impact of the use of forest commodities in supply chains, including how to align its approach with the EU’s Deforestation Regulation, which has undergone a number of simplifications since it was adopted. However, the timeline for adoption of any implementing legislation remains unclear.
