FAQs: UK Forest Risk Commodity Regulation (UKFRC) and EU Deforestation Regulation (EUDR)

In 2021, the Department for Environment, Food and Rural Affairs (Defra) announced that provisions under the Environment Act would introduce a due diligence requirement on certain forest risk commodities.

This would prohibit larger companies from using agricultural commodities that have not been produced in line with local laws in the countries where they originate. This followed two government consultations in both 2020 and 2021.

After a pause in implementing the legislation, Defra had signalled its intent to do this before the last General Election but the legislation was not laid prior to the dissolution of Parliament.

Yes, in June 2026 the new (Labour) Government announced plans to introduce new rules in GB to tackle illegal deforestation in supply chains, with a consultation on the proposed GB deforestation policy expected later in the year. There are significant differences in these updated plans, and they also raise a number of questions which AIC will seek to answer.

The Department for Environment, Food and Rural Affairs (Defra) originally confirmed that the following products will be in scope:

• Non-dairy cattle products (beef and leather)

• Cocoa

• Palm

• Soya

The June 2026 announcement confirms that the list of products in scope has now been extended to reflect the relevant commodities listed in Annex I of the European Union Deforestation Regulation (EUDR). The list now extends to:

• Wood

• Cattle

• Cocoa

• Coffee

• Palm oil

• Rubber

• Soya

• Certain derived products, such as chocolate and furniture

It is not clear from the June 2026 announcement how dairy products will be treated. Under the original UK Forest Risk Commodity Regulation (UKFRC) scope, dairy products would be separately in scope where they are derived from animals fed on a diet that contains a forest risk commodity, such as soya or palm kernel expeller.

In the original UK Forest Risk Commodity Regulation (UKFRC) scope, raw or primary forest risk commodities, and all products derived from these commodities, would be regulated. This includes products that may currently be considered as “waste products” or “by-products”, such as:

• Soya hulls

• Palm kernel expeller

• Hides from a bovine animal

However, it is not clear from the June 2026 announcement whether these derived products will be in scope. The announcement refers to ‘certain derived products such as chocolate and furniture’, but no further detail is provided.

If it is the Government’s intention to implement regulations with the same scope of relevant commodities as the European Union Deforestation Regulation (EUDR), then palm kernel expeller and other palm derivatives will be in scope, but soya hulls will not be.

The original UK Forest Risk Commodity Regulation (UKFRC) scope confirmed that organisations using these commodities in UK supply chains, with a global turnover of over £50 million, would be in scope of the regulation.

The June 2026 announcement states that businesses in Great Britain (GB) with an annual turnover of over £1 million, which use forest risk commodities and wood products, will be required to carry out due diligence.

In addition, the original scope set out that organisations whose use of the regulated commodities does not exceed an annual volume threshold of 500 tonnes may submit an exemption.

There is no reference to de minimis volumes of relevant commodities in the June 2026 announcement.

AIC has had regular contact with the Department for Environment, Food and Rural Affairs (Defra) teams which are working on UK Forest Risk Commodity Regulation (UKFRC).

Engagement to date has included AIC participating in workshops and contributing to consultation exercises, as well as holding constructive one-to-one meetings with policymakers.

Defra has indicated that there will be a need for continued engagement with industry representatives to support the drafting of the guidance that will accompany the legislation.

Following the June 2026 announcement, AIC will seek meetings with UKFRC teams to consider the detail of the announcement and address the questions it raises.

Passing the secondary legislation through both Houses of Parliament would take at least four months, following a consultation planned for later in 2026. In the original UK Forest Risk Commodity Regulation (UKFRC) proposals, the Government indicated a possible ‘grace period’ of six months.

The June 2026 announcement provides no detail on transition periods.

AIC contact with the current Labour Government has confirmed that the legislation is still regarded as a priority. However, the Government has given little indication as to when they might find the necessary Parliamentary time to pass the legislation into law.

In March 2025, Defra and ICF launched a survey to enhance their understanding of supply chain management for commodities such as soy, palm, rubber, timber, leather, beef, cocoa and coffee.

AIC understand that a new Defra team is now working on UKFRC and the survey is intended as an information gathering exercise. AIC have contacted the new Defra team to seek an initial meeting.

Passing the secondary legislation through both Houses of Parliament would take at least 4 months, following a consultation which is planned for later in 2026.

In the original UKFRC proposals Government indicated a possible ‘grace period’ of six months.

The June 2026 announcement gives no detail relating to transition periods.

The Department for Environment, Food and Rural Affairs (Defra) originally committed to providing comprehensive guidance on the type and scope of evidence that businesses in scope will be expected to provide in their annual compliance reports. AIC sees no reason why this commitment would not be met following the June 2026 announcement.

It is not yet clear whether this guidance will be published at the same time as the secondary legislation is laid.

The original scope of the UK Forest Risk Commodity Regulation (UKFRC) was not a ban on importing forest risk commodities in scope. This position has not been altered by the June 2026 announcement.

The regulation will require businesses in scope to submit an annual compliance report confirming that products in scope have been produced in accordance with local laws.

Given this, AIC does not anticipate any immediate impact on the availability of certain commodities as a result of the implementation of UKFRC.

No indication is given in the June 2026 announcement of the competent authority to implement the regulation in GB.

The June 2026 announcement states that the aim is to ensure the GB proposals operate consistently alongside the European Union Deforestation Regulation (EUDR). The list of relevant commodities has also been amended to reflect those listed in Annex I of EUDR, but no reference is made to embedded commodities.

Reference is made to certain derived products, such as chocolate and furniture, but it is not clear whether this is a definitive list.

If embedded commodities are not in scope, this raises the question of whether livestock-derived products, such as pork, poultry and eggs, can be imported into the UK from outside the EU without importers having to carry out due diligence or provide evidence that any forest risk commodities embedded in those products (such as soya and palm in feed) are free from deforestation.

If it is the Government’s intention to implement regulations with the same scope of relevant commodities as EUDR, embedded commodities would not be in scope. However, it is not clear from the June 2026 announcement whether this is the intention, and AIC will be seeking urgent clarification of this.

The June 2026 announcement confirms that the European Union Deforestation Regulation (EUDR) will apply in Northern Ireland from 30 December 2026. The Government states that their ‘aim in Great Britain is to ensure aspects of the scope and information requirements are broadly the same as those of the EUDR. This is to reduce regulatory divergence between Great Britain and Northern Ireland and support trade with the EU. It is our intention that the due diligence requirements in Great Britain will require businesses to hold similar information as under the EUDR, avoiding duplication of business burdens and disincentives to trade.’ 

The June 2026 announcement does not make it completely clear whether businesses in Northern Ireland need to comply with GB regulations as well as EUDR.

Given the June 2026 announcement, it is clear that the UK Forest Risk Commodity Regulation (UKFRC) is now much closer in scope to the European Union Deforestation Regulation (EUDR). However, there remain uncertainties and gaps following the announcement, meaning that a full and accurate comparison cannot yet be established.

AIC has been made aware that, unlike the EUDR, UK controls will not operate at the point of import. AIC will provide further clarity on this, along with the many other considerations, once it has received responses from the Department for Environment, Food and Rural Affairs (Defra) on these uncertainties and gaps.

Agri-supply businesses in scope will be required perform due diligence to make a judgement on forest-risk commodity sourcing and the integrity of their supply chain.

They will need to map their supply chain and assess the risk of illegality, creating a risk management plan. This plan will need to be actioned in order to mitigate identified risks to a level as low as reasonably practicable.

Businesses will need to submit an annual report on this due diligence activity. The Department for Environment, Food and Rural Affairs (Defra) has stated that the information required will be detailed in published guidance.

In the June 2026 announcement, the Government states that businesses using these products will need to establish a due diligence system, report on their activity, and retain evidence of compliance, including collecting geolocation data on the origin of the specific products.

The requirement for geolocation data is aligned with the European Union Deforestation Regulation (EUDR); however, this data will form part of the evidence included in an annual due diligence report and will not be required at the point of entry into GB.

AIC has developed two modules under the AIC Sustainable Commodities Scheme

The Scheme aims to provide feed and food supply chains with confidence that soya and palm commodities have not originated from deforested land. It is relevant to importers, traders and compound feed manufacturers.

• Module 1 is applicable to shippers, importers and exporters to demonstrate alignment with the requirements of the European Union Deforestation Regulation (EUDR).

• Module 2 is applicable to compound feed manufacturers and feed ingredient suppliers using feed products in the UK to demonstrate that the deforestation-free status of products supplied to livestock producers and downstream customers is maintained.

The Scheme details and standards can be found here:​ AIC | ASCS - AIC Sustainable Commodities Scheme

AIC will work to develop a module reflecting the new requirements of the UK Forest Risk Commodity Regulation (UKFRC), as set out in the June 2026 announcement, once the uncertainties and gaps have been resolved.

Under the EU Deforestation Regulation (EUDR), any operator or trader who places commodities - such as soya, beef, palm oil, wood, cocoa, coffee, rubber - on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have contributed to forest degradation.

Relevant goods must also be covered by a due diligence statement and be produced in accordance with applicable local laws.

EUDR was introduced in June 2023. As of 30 December 2024, the key articles of the EUDR will apply, leaving a short adaptation and preparation period. 

However, on 2 October 2024 the European Commission announced proposals to delay the implementation of EUDR by 12 months and this was confirmed on 18 December 2024.

The regulation (2023/1115) can be found on the European Commission website.

Yes, the formal adoption of the European Commission proposal to delay the implementation of EUDR by 12 months was confirmed on 18 December 2024. All relevant documents are available on the European Council website.

On 2 October the European Commission announced proposals to delay the implementation of EUDR by 12 months.

The proposal moves the date of implementation to 30 December 2025 for large companies, and 30 June 2026 for small companies.

On 2 October, the EU Commission published additional guidance documents. Click below for the latest information:

• Press release
• Guidance
• Proposal for a Regulation amending Deforestation Regulation as regards the date of application
• Third edition of FAQs
• Strategic Framework for Cooperation
• SME factsheet
• Mythbuster

On 4 March 2025 the European Commission published a document with a 10 scenario overview of how the EUDR requirements would apply depending on the company type (operator/trader) and company size and position in the supply chain.

This non-legally binding publication, "Understanding your company position in the supply chain under the EUDR" should be read alongside the EUDR FAQ and Guidance document. The scenarios cover the relevant products in scope of the regulation as listed in Annex I.

In one of the scenarios set out in the document published on 4^th March 2025, the description of the sale of soybean meal by oilseed crusher to a feed mill provides the first explicit reference that compound feed is not part of the EUDR scope.

“Oilseed crushing facility A sells the soymeal (HS 1208) to feed mill B, which blends the soymeal with other ingredients like grains and minerals to produce compound feeds (HS 2309) for livestock. As compound feed is not a relevant product under EUDR (Annex I), feed mill B does not have obligations under EUDR for this product (FAQ. 2.1).”

This reference is consistent with the viewpoint that compound feed lies outside the scope of the regulation delivered via a legal opinion sought by FEFAC on behalf of the European feed industry.

The legal opinion stated:

‘According to Article 2 No 2 of the EUDR, relevant products are only those which are listed in Annex I on the basis of the corresponding goods tariff number. Compound feed of HS heading 2309 is not mentioned in Annex I. The mere fact that relevant commodities, notably soya, are contained in a product is not sufficient for the application of the EUDR (see European Commission, FAQ as of October 2024, No. 2.1).’

Recital 39 states that ‘operators placing on the market or exporting relevant products that contain or have been made using cattle which have been fed with relevant products that contain or have been made using other relevant commodities or relevant products, should ensure, as part of their due diligence system, that the feed is deforestation-free’

The EU Commission document published on 4^th March 2025 and the legal opinion delivered to FEFAC would suggest that compound feed lies outside the scope of the regulation, whether it contains ‘relevant products’ or not.

The Commission document still leaves room for some confusion as it refers to “soymeal feed” and “cattle feed” which do not have a clear legal status.

If cattle, supplying beef to the EU market, are fed straight soya or palm products listed in Annex I then it is clear that these fall within the scope of the regulation and evidence may need to be provided that these ’relevant products’ are deforestation free.

A compound feed is defined in legislation as ‘a mixture of at least two feed materials, whether or not containing feed additives, for oral animal-feeding in the form of complete or complementary feed’. Given this, livestock farmers buying straights and mixing them to prepare a ration (TMR etc) are preparing a compound feed.

Similarly, a blend is compound feed assuming it meets the definition above.  

AIC has been in regular discussions with meat and dairy industry organisations, producer representatives and retailers. We will point our members to any published guidance as and when this becomes available.

Prior to placing relevant commodities on the EU market, agri-supply businesses must carry out mandatory due diligence to ensure these products are deforestation-free and legally produced (based on a cut-off date of 31 December 2020).

Critically, companies must provide geo-location co-ordinates for commodities providing traceability and evidence that they have not been produced on recently deforested land. 

In March 2025, the EU Commission published a new training video concerning the EUDR Information System.

This video is longer than those previously published and can be found on the dedicated webpage - https://green-business.ec.europa.eu/deforestation-regulation-implementation/information-system-deforestation-regulation_en#training-videos

AIC is an active member of the European feed industry federation FEFAC, and is engaged with a number of FEFAC group working on EUDR.

FEFAC has joined forces with the European association of trade in cereals, oilseeds, rice, pulses, olive oil, oils and fats, animal feed and agrisupply - COCERAL - and FEDIOL, the European vegetable oil and proteinmeal industry association, to represent the combined interests of the agri-supply sector with the various EU decision making bodies.

There is concern that the lack of clarity over EUDR is affecting the market for soyabean meal, particularly for contracts from 4th Quarter 2025 onwards, and it is true that for EUDR, many uncertainties remain.

European trade association FEFAC, of which AIC is a member, has written to David Clarinval, EU farm minister, expressing concern at the impact of EUDR uncertainty on feed security.

FEFAC calls on the EU Council to focus on delivery of a functional IT system as a matter of urgency and to consider phasing in traceability requirements over a period of time.

FEFAC also recommends making use of existing traceability tools, such as the FEFAC Soy Sourcing Guidelines, as part of this transition.

Visit the FEFAC website for more detail.

In February 2025, FEFAC, COCERAL and FEDIOL called for EUDR to be included in the scope of the EU Omnibus Simplification package. The call included specific recommendations which were:

• Removal of alleged obligation for cattle farmers that their feed is deforestation-free, as part of their due diligence requirements (Recital 39)
• Limit the obligations for complying with Article 3 to first-placers on the EU market of relevant products (Article 5)

There is no doubt that whilst EUDR will not be implemented in Great Britain (it will apply in Northern Ireland), similar impacts to those seen in EU will be seen in UK.

AIC would recommend feed compounders remain in regular contact with their soya suppliers. AIC will provide further clarity on EUDR as soon as this becomes available.

To date (March 2025), UK Government has not appointed a competent authority for the implementation of the regulation in Northern Ireland.

AIC understands that a competent authority will be appointed following the publication by the EU Commission of the country deforestation risk classification system (benchmarking system). This is expected to be complete by June or July 2025.

EU Commission has published a list of EUDR competent authorities

AIC has developed a voluntary, EUDR aligned standard under the AIC Sustainable Commodities Scheme (ASCS). The EUDR Aligned Module sets out to demonstrate that Participants handling products within the scope of EUDR have systems in place which are aligned with the requirements of EUDR.

The EUDR Aligned Module cannot confirm that Participants are compliant with the requirements of EUDR, as compliance can only be assessed by the appointed competent authorities. However, being a certified Participant will help meet the regulatory requirements, as appropriate documented procedures and processes will be in place. The definitions used in the module for forest and deforestation are common to those set out in the Regulation. The module requires that no legal or illegal deforestation has taken place since 31st December 2020.

AIC consulted on the draft standard in December 2024 and produced a consultation pack. Following consultation responses the draft standard is under review.

Some supply chain partners have confirmed the requirement to demonstrate that commodities in scope of EUDR and used in feed, are compliant with the requirements of the Regulation.

This is to help ensure the maintenance of market access to the EU for other in-scope commodities such as UK beef supplied from beef and dairy producers.

Other supply chain partners, including the UK Soya Manifesto signatories, have indicated their intention to require their livestock farming suppliers to use ‘EUDR compliant’ soya in feed as a stepping stone towards the Manifesto commitment of using verified deforestation and conversion free soya in their supply chains by the end of 2025.

AIC’s EUDR Aligned Module will be used by these supply chain partners as evidence to verify that the in-scope commodities in feed, supplied by certified Participants in the ASCS, are considered aligned with EUDR requirements.