EU Deforestation Regulation (EUDR) - Part 1
In this first episode of a two-part series, Ed Barker, AIC Head of Policy and External Affairs, and James McCulloch, AIC Head of Feed, unpack the fundamentals of the EU Deforestation Regulation (EUDR), a pivotal regulatory development influencing the agri food sector and global agricultural supply chains. Focusing on the agri food supply in the UK, we explore what the EUDR means for the UK feed and farming sectors.
Part 1 covers the essentials of sustainable sourcing and feed supply chains: where the UK currently sources its soya, why alternative proteins are not yet fully scalable, and the policy frameworks shaping future trade and market access.
Ed and James explain what the EUDR actually is, how it interacts with emerging UK legislation, and why these changes matter for importers, feed manufacturers, farmers, and anyone navigating compliance and sustainability in modern agriculture.
This episode is ideal for listeners looking for clear, practical insight into EUDR compliance, sustainable soya sourcing, UK feed regulation, and the wider impact on agri‑supply businesses.
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Transcript
00:00:06 Wendy: Welcome to the AIC Podcast,
00:00:08 Wendy: where we share practical guidance and insight for Members and help the industry understand how the agri‑food supply chain works. I’m Wendy Ford, the AIC Communications Manager, and today we’ll explain what the EU Deforestation Regulation is, why soya matters, what’s happening in the UK, and what it means for farmers and feed businesses. I’m joined by Ed Barker, AIC Head of Policy and External Affairs, and James McCulloch, AIC Head of Feed. Why is soya such an important raw material for the UK animal feed industry, and where does the UK source it from?
00:00:43 James: The UK sources soya from four major origins: Argentina, Brazil, Paraguay and North America — largely the US. It’s a very important component of animal feed because of its protein content — high protein, around forty‑five to forty‑eight per cent. It has a fantastic amino acid profile, particularly suitable for monogastrics. It’s available all year round in sizeable quantities and offers a strong value proposition for our feed compounder Members. So it’s an important and valuable raw material.
00:01:25 Wendy: Thanks, James. That sets the scene really well. What would you say are the challenges in replacing soya with UK‑produced protein sources?
00:01:33 James: Alternatives would again focus on high‑protein sources. We’d be looking at oilseed rape meal and some other oilseed meals. Generally speaking, those alternatives are not available locally or in as large quantities as soya, and the protein content and amino acid profile are not quite the same. So it’s difficult to say they are direct replacements — they are alternatives. But we would certainly like to be able to source more alternatives locally.
00:02:08 Ed: Yeah. It’s one of the most common questions we get — why can’t we just replace soya with UK‑grown pulses and oilseeds? I think James has set out the challenges. We also can’t overlook the fact that UK production, particularly in the oilseed sector, has seen a consistent decline over the last ten to fifteen years — especially due to pest pressure and the removal of neonicotinoids. About fifteen years ago we were producing around 2.2 million tonnes UK‑wide. Last year that was down to around seven or eight hundred thousand tonnes. This year, interestingly, was a very good year for oilseed rape — forecast at around seven to eight hundred thousand tonnes but nearer nine hundred and fifty thousand in reality.
Similarly for pulses, they’ve always been about five per cent of the arable area, and growers often go in and out of them depending on confidence. Another challenge has been that some SFI options have directly competed with growing pulses. So domestic supply has always been a challenge. And as you say, James, it’s easy when there’s a high‑protein feed material available on your doorstep — but that doesn’t mean we shouldn’t be looking at domestic pulses and oilseeds. Absolutely we should. But in the meantime, monogastric sectors — and dairy — have to be fed 365 days a year. They can’t wait for initiatives or government policy.
00:03:47 Wendy: Building on that point about availability and suitability of alternatives: what does that mean in terms of scale? How much extra production or land would be needed if we tried to replace soya with UK‑grown pulses?
00:04:01 James: One major issue with pulses is that peas and beans come in at around twenty‑five per cent protein, compared with soya at forty‑eight to fifty per cent. So for every tonne of soya you need roughly two tonnes of peas or beans — and the land to grow them. We use about two and a half million tonnes of soya. To replace that, we’d need around five million tonnes of peas and beans. So it’s a very large acreage. That’s not to say we shouldn’t encourage more local production.
00:04:37 Wendy: That’s really helpful context. Can you talk us through the EUDR rules and what they mean for suppliers trying to get products into the European market?
00:04:49 James: The EUDR — the European Union Deforestation Regulation — was first proposed three years ago and has probably been one of the most troublesome regulations ever devised by the EU. The fact it’s still not implemented suggests the drafting left something to be desired. Everyone supports the principle of preventing deforestation, including industry, but the means by which the Commission is proposing to deliver it is where the challenge lies.
00:05:37 Ed: It effectively requires a commodity to be audited to the nearest square metre using geolocation to show exactly where it was grown. It covers not just soya, but palm, coffee, cocoa and others. To place a product on the EU market, you must provide geolocation coordinates annually. These are global commodity products that move around the world — they’re not widgets — and you can immediately see the difficulty of tracing soymeal or cocoa all the way back to origin using geolocation. That’s partly why, three years later, the legislation still isn’t in place.
00:06:37 James: And again, the risk for those in the supply chain is that the regulation applies at the point of entry — the point of import. If you don’t have the evidence Ed described, you would be prevented from placing the product on the market, with all the costs that involves. It’s quite a high bar the EU has set.
00:07:05 Wendy: Looking beyond the EU rules, can you explain the UK’s own deforestation regulations and how they differ from the EUDR?
00:07:17 James: The UK proposed its own approach in the Environment Act 2021.
00:07:28 Ed: Yes — it was first announced at the end of 2020, just as I joined AIC, which was even before the EU began its legislative process.
00:07:40 James: The UK’s proposal — the Forest Risk Commodity Regulation — is markedly different to the EU’s. It aims for the same outcome: deforestation‑free supply chains. But it covers both deforestation and conversion, and it doesn’t apply at the point of import. Instead, it requires businesses in the supply chain to undertake due diligence and publish an annual report showing how they ensured the commodities they handled were not linked to deforestation.
00:08:20 Ed: Unlike the EU, it’s essentially an enhanced risk assessment. No geolocation of the product. And it applies to everyone in the supply chain, not just importers — including processors and retailers, where soya is embedded further along. That’s a big point of difference.
00:08:55 Wendy: So looking at where things stand now, what’s the current timeline for EUDR implementation?
00:09:01 James: Implementation has now been delayed for a second year, so it’s anticipated to come into force on 30 December 2026. The text now requires any revision to be tabled by 30 April 2026. Over the past two years we’ve entered late 2024 and 2025 without knowing the final terms or whether it would even be implemented, which has been problematic. The EU wants to avoid that Groundhog Day in 2026, so if revisions are coming, we should see them by the end of April.
00:10:00 Ed: Also, when it was originally proposed three or four years ago, the political landscape was entirely different — new Commission, new Parliament, different UK government. Environmental legislation was much higher on the agenda, with net zero commitments everywhere. That now feels a lifetime ago after the cost of living crisis, inflation and Ukraine. The fact the EU has had to postpone implementation twice suggests the gap between theory and practice still hasn’t been bridged. And although the UK legislation was passed in 2021, it’s now 2026 — though we’ve had several governments and ministerial changes since then.
Everyone agrees the regulation must avoid adding to inflation and must actually help eliminate illegal deforestation. But there’s concern that parts of what’s been proposed may not genuinely help reduce deforestation globally.
00:11:51 James: Absolutely. When I go to Brussels the mood music has changed dramatically — much more emphasis on European food security and production. So even with noble aims, any regulation that affects feed availability — and therefore food — must be considered carefully.
00:12:23 Wendy: Given all that uncertainty, how likely is it that the EUDR will be amended before implementation? And what sort of changes should the supply chain expect?
00:12:38 James: The revised text allows for amendments, and there’s been a big push to include EUDR in an omnibus simplification package — essentially watering down some proposals or adjusting implementation. But substantial changes seem unlikely. Despite everything, the green bloc in the European Parliament is still strong. We may see some tweaks around the edges, but I think there’s an appetite now to implement the regulation and see how it works.
00:13:31 Ed: And it’s not very long. If we’re talking end of March, that’s not much time in EU legislative terms. Past delays have been more out of necessity than intent. Without urgency from the Commission — and with implementation not until 2027 — it’s unclear what substantial changes we’ll see. Maybe phased reporting or suspended checks at first, but it’s not long. For a commodity supply chain that buys years in advance, the uncertainty is hugely destabilising for global trade and for providing consistent pricing to farmers in Europe and the UK.
00:15:02 James: And it won’t surprise anyone that the IT system has been one of the biggest challenges — storing and processing huge geolocation files and data. The Commission hasn’t demonstrated that the system can work while maintaining the flow of goods. More time may allow improvements, but big changes — such as introducing a “zero deforestation” category to exempt certain regions — now seem unlikely.
00:15:47 Wendy: So that’s part one.
00:15:50 Wendy: We’ve covered why soya remains pivotal, the limits of UK substitutes, and the EU’s EUDR — what it asks for and why implementation has been challenging. In part two, we’ll look at the UK’s own approach, key differences from the EU, and what businesses can do now — including how the AIC Sustainable Commodity Scheme supports information flow through the chain. Join us next time.
00:16:21 Wendy: The views and opinions expressed in this podcast are those of the hosts and guests and do not necessarily reflect any organisation they represent. This content is for informational purposes only and should not be considered professional advice. Listener discretion is advised. Thank you.
