EU Deforestation Regulation (EUDR) - Part 2
In this second part of this two‑part episode, Ed Barker, AIC Head of Policy and External Affairs, and James McCulloch, AIC Head of Feed, move beyond the global context and focus on what the European Union Deforestation Regulation (EUDR) means in practice for the UK supply chain.
The conversation explores the UK’s developing approach to deforestation‑free regulation, how it aligns with or diverges from the EU’s EUDR framework, and the unique position of Northern Ireland, which remains directly in scope.
Ed and James unpack current policy signals, expected timelines, and the practical realities businesses need to prepare for, including traceability requirements, due diligence obligations, and evolving customer expectations across retail, processing, and feed manufacturing.
Ideal for listeners seeking clear, practical guidance on navigating EUDR requirements, this discussion helps build understanding of the UK’s emerging deforestation‑free rules and what feed and agri‑supply businesses should be preparing for next.
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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 in Part One we explored soya’s role and the EU’s EUDR. Today we focus on the UK — what’s in the Environment Act framework, how it differs from the EU model, and what that means in practice. With me again are Ed Barker, AIC Head of Policy and External Affairs, and James McCulloch, AIC Head of Feed. Let’s get back into the practical issues for the UK. How does the EUDR apply in Northern Ireland?
00:00:46 James: Complicated.
00:00:49 Ed: It’s worth saying that until recently, there has been quite a large discussion about the extent to which EUDR actually applies in Northern Ireland — which you’d like to think is something we’d have had clarity on far sooner. The working assumption when EUDR was introduced was that it would apply in Northern Ireland, which was slightly quizzical because it’s not a phytosanitary issue; it’s arguably more of a customs issue.
This has rumbled on while we’ve tried to understand how the UK intends to approach application in Northern Ireland. Around November or December last year, Government effectively said it would not regulate or implement EUDR itself in Northern Ireland, and that this would fall to the European Commission. For traders in Northern Ireland trying to operate within a clear legal framework, that wasn’t very helpful.
00:01:59 James: No, it wasn’t. The Government’s line was essentially that it didn’t have the executive powers required to appoint a competent authority to implement the regulation in Northern Ireland. AIC Members operating there may serve a local market, but most also supply the Republic of Ireland and wider EU. They see the need to comply — or be seen to comply — as essential for market access. If they can’t demonstrate compliance because the regulation is not implemented or doesn’t apply, that becomes a challenge. Hopefully we’ll see some clarity during the first half of 2026 on how the Government intends to manage EUDR in Northern Ireland.
00:02:57 Ed: Something tells me we’ll be in a similar position in Q3 or Q4 this year, still asking what businesses on the ground are actually supposed to do. I hope I’m wrong, but it’s where we’ve been for the past two years.
00:03:12 Wendy: And that brings us to the UK’s own position. Where do things currently stand with the UK’s deforestation rules under the Environment Act?
00:03:21 James: Interestingly, towards the end of 2025, teams within Defra and other departments reopened conversations about what to do with the originally proposed UK Forest Risk Commodity Regulations. They were sounding out industry and supply chain partners — not just on the original UK proposals but also on EUDR itself. That suggested to us that Government might be prepared to open up the Pandora’s Box of the Environment Act 2021, pull out the UK FRC proposals, and have another look at them. Ed, I don’t know what you think?
00:04:11 Ed: There are two things at play. First — and people often forget this — the legislation is already in place. The Environment Act, passed in 2021, already contains the UK’s deforestation provisions. What’s missing is the secondary legislation — the detailed rules explaining how it would work in practice: what businesses must report, what processes they must follow, how due diligence is applied. We’ve never reached that stage. It has simply sat on the statute book without implementation.
Second is how the UK and EU models compare. Some people say, “Why don’t we just adopt the EU proposals?” But the Environment Act is written in a very specific way. You couldn’t just copy‑and‑paste EUDR into UK law without fundamentally changing the primary legislation — which, as anyone familiar with politics knows, is slow and complex.
Government recognises that having two entirely separate compliance systems — one for the UK and one for the EU — is burdensome, especially for businesses trading across both. But it’s about navigating a path that doesn’t add unnecessary complexity or cost, particularly at a time when inflation and food prices are major political priorities.
00:07:03 James: I agree. The businesses we represent generally regard the UK proposals as more pragmatic and manageable — an enhanced risk‑assessment exercise with retrospective reporting a year later, rather than blocking imports at the point of entry. If you flipped the question and asked whether the EU would adopt the UK model, clearly they wouldn’t. But our members felt the original UK approach would achieve the same environmental aims in a more practical way.
00:08:06 Wendy: Another area that often causes confusion is how deforestation rules apply to animal products themselves. Can you explain what embedded commodities are and how deforestation regulations affect these products?
00:08:21 James: Embedded commodities refer to commodities that appear within other products. For example, eggs or chicken on a retail shelf contain embedded soya because the birds were fed feed containing soya. If a regulation includes embedded commodities within its scope, suppliers of eggs or chicken must demonstrate that the soya in the feed was compliant with the deforestation rules.
The original UK proposals did include embedded commodities, requiring businesses to account for embedded soya across thousands of different products — a complex exercise. EUDR does not include embedded commodities, which is a significant difference.
00:09:27 Ed: If you’re a European farmer, your main concern is cost — the cost of geolocation, auditing, segregation, and the administration required by EUDR. European farming groups were very vocal last year about rising feed costs and competitiveness impacts.
In the UK, there is still a cost implication, but under the UK model the issue is that farmers buy from businesses in scope and sell to businesses in scope. The question becomes: how do you pass information about the soya in your supply chain — from the feed supplier to the processor or retailer? That is something Government has not fully answered, and the supply chain is having to develop solutions itself. AIC has been working with partners across the chain on exactly this.
00:11:18 James: Yes — it’s about providing transparency and enabling information to flow. Our role in the feed sector is to pass on verified information to immediate customers — livestock farmers, processors and retailers. To support that, we’ve developed the AIC Sustainable Commodities Standard to help information move through the chain.
Although EUDR doesn’t apply in Great Britain, certain processors and retailers will still specify “deforestation‑free” or “EUDR‑compliant” product from their suppliers. So transparency requirements will continue regardless. One of our roles is to help facilitate that market.
00:12:42 Wendy: You’ve mentioned the need for transparency and verified information. How does the AIC Sustainable Commodities Standard work, and how would it help businesses prove compliance?
00:12:57 James: The scheme applies to importers of in‑scope commodities and to feed manufacturers using those commodities. Participants must demonstrate to an independent, third‑party auditor that they have sufficient information to show the commodities they handle are compliant with relevant legislation.
The first standard within the scheme is aligned with EUDR. We cannot call it “EUDR‑compliant”, because only competent authorities can confer compliance. But we can assess whether a commodity would meet EUDR requirements. Participating businesses can then demonstrate to downstream customers — farmers, processors, retailers — that they meet the standard, and that the feed they supply is compliant. It is essentially an audited accounting exercise tracking flows of material into and out of feed mills and through to farms.
00:14:29 Wendy: That’s great — and yes, all the information is available on our website. It’s an open‑access area, not restricted to Members. If you want to find out more, please head to agindustries.org.uk. Finally, taking a step back from all the detail: if our listeners take away one thing from this podcast, what should it be?
00:14:53 James: From my point of view, looking at the food sector and our Members and their customers, it’s clear this is a complex area and a long‑running saga. The regulations will definitely have economic impacts. Our role at AIC is to be as informed as possible, maintain regular dialogue with FEFAC, with UK Government, and with the whole supply chain — farmers, livestock associations, UK Soya Manifesto signatories, WWF and others — to ensure there are no surprises.
We’ve also tried to facilitate the market through the Sustainable Commodities Standard. And if you’re sitting in an office unsure about your soya sourcing or what to expect, get in touch. We may not have every answer, but you’ll certainly realise you’re not the only one trying to make sense of it.
00:16:50 Ed: Yes — soya underpins not just the UK food system but the global food system. The regulations being developed in the UK and EU matter for sustainability, deforestation, food security and inflation. Whether you’re a farmer, part of the supply chain, an NGO or policymaker, this may seem peripheral at times but it does matter. The decisions taken over the next year will have a major impact. It’s a shared endeavour to ensure legislation is workable, maintains a functioning food system, and helps combat illegal deforestation — which is something everyone agrees on.
00:18:15 Wendy: That’s great — thank you so much for today.
00:18:18 Wendy: That’s a wrap on Part Two. We’ve compared EU and UK approaches, discussed timelines and politics, addressed Northern Ireland and shared practical ways to keep information moving. For details on the AIC Sustainable Commodities Standard and resources mentioned today, visit our website. As ever, we’ll keep collaborating across the supply chain as the picture evolves. Thank you to Ed and James, and thank you for listening. Until next time, goodbye.
00:18:45 James: Thank you.
00:18:47 Ed: Thank you. Goodbye.
00:18:55 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.
