As global concern over deforestation continues to grow, governments are introducing legislation to ensure that products entering their markets are sourced responsibly. Two of the most significant regulations affecting businesses are the European Union Deforestation Regulation (EUDR) and the UK’s proposed Forest Risk Commodity Regulation (UKFRC).
While both regulations share the common goal of reducing deforestation and improving supply chain transparency, they differ significantly in scope, legal requirements, and implementation. Understanding these differences is essential for businesses operating across both UK and EU markets.
What is EUDR?
The European Union Deforestation Regulation (EUDR) is designed to ensure that certain commodities and finished products imported to, sold within, or exported from, the EU are:
Deforestation-free (not produced on land deforested after 31 December 2020)
Produced in accordance with the laws of the country of origin
Supported by a formal Due Diligence Statement before being placed on the EU market
The regulation covers seven key commodities:
- Cattle
- Cocoa
- Coffee
- Palm oil
- Rubber
- Soy
- Wood
It also applies to a wide range of derived products including chocolate, leather, furniture, paper, tyres and many timber products. Companies must collect geolocation coordinates for the land where the commodities were produced, conduct risk assessments, implement mitigation measures where necessary, and submit due diligence information through the EU’s Information System.
What is UKFRC?
The UK Forest Risk Commodity Regulation (UKFRC) is the UK’s forthcoming framework under the Environment Act 2021. Following a policy announcement in June 2026, the UK Government confirmed its intention to introduce legislation requiring businesses in Great Britain to carry out due diligence on forest risk commodities.
Unlike the EUDR, the UKFRC is initially focused on preventing the use of commodities produced illegally under the laws of the country of origin, rather than requiring products to be entirely deforestation-free. However, the Government has stated that it intends to move towards a fully deforestation-free standard in the future.
The Main Differences
1. Legal Standard
2. Geographic Scope
EUDR requires products to be both:
Deforestation-free and legally produced.
If land has been deforested after 31 December 2020, the products cannot enter the EU market regardless of whether the deforestation was legal under local laws.
UKFRC initially focuses on legality. Businesses must demonstrate that commodities have been produced in compliance with the relevant laws of the producing country. The UK Government has indicated that it intends to transition to a broader deforestation-free standard over time.
EUDR
Applies to businesses importing, placing products on the EU market or exporting products from the EU.
UKFRC
Applies to businesses operating within Great Britain. Northern Ireland will continue to follow the EUDR under the Windsor Framework, meaning companies trading across the UK may need to comply with both regimes depending on where products are placed on the market.
3. Business Thresholds
4. Due Diligence Requirements
EUDR
The obligations apply to operators and traders, with varying responsibilities depending on company size.
UKFRC
Current proposals indicate that businesses with an annual turnover exceeding £1 million using forest risk commodities would be required to implement due diligence systems. This is a significant reduction from earlier proposals, which targeted only organisations with turnover above £50 million.
Both regulations require companies to:
- Map supply chains
- Assess sourcing risks
- Retain supporting evidence
- Collect geolocation data
- Maintain due diligence systems
However, the implementation differs.
Under the EUDR, a Due Diligence Statement must be submitted before products enter the EU market.
The UKFRC is expected to require businesses to maintain due diligence records and submit periodic reporting, rather than operating as an import approval system.
EUDR regulations cover:
- Cattle
- Cocoa
- Coffee
- Palm oil
- Rubber
- Soy
- Wood
The EUDR already has an extensive list of derived products.
The UK has stated that it intends to align closely with the EUDR by including certain derived products such as chocolate and furniture, although the final scope remains subject to consultation.
Despite their differences, both regulations require businesses to improve supply chain transparency by:
- Understanding where commodities originate
- Collecting reliable supplier information
- Recording geolocation data
- Conducting documented risk assessments
- Maintaining evidence for regulatory inspections
For companies already preparing for EUDR compliance, many of the systems developed such as supplier mapping, geolocation collection and traceability are expected to support future compliance with the UKFRC as well.
Practical Implications for Businesses
Companies trading in both the UK and EU should avoid treating these as entirely separate compliance exercises. Instead, organisations should consider implementing a unified due diligence framework capable of satisfying both sets of requirements.
Key priorities include:
- Establishing robust supplier traceability systems.
- Collecting accurate farm or production-site geolocation data.
- Conducting documented risk assessments.
- Maintaining auditable records throughout the supply chain.
- Monitoring regulatory developments as the UK finalises its legislation.
Businesses that invest in comprehensive supply chain transparency today are likely to be better positioned to comply with both the EUDR and the UK’s evolving Forest Risk Commodity Regulation.
The EUDR is already a defined regulatory framework with detailed due diligence requirements. By contrast, the UKFRC is still being developed, with a limited timeframe between legislation and guidance being published and the expected implementation in Great Britain. The UK Government has made clear that it intends to align many of the information requirements with the EUDR to minimise duplication for businesses operating across both markets while retaining its own legislative approach.
For organisations sourcing forest-risk commodities, the direction of travel is clear, greater transparency, stronger due diligence, and increased accountability throughout global supply chains. Those who prepare early will be best placed to meet regulatory expectations while demonstrating a genuine commitment to sustainable sourcing.
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