Introduce Forest Risk Commodities Legislation

Clean environment & nature — Helps

moderate · low confidence

This legislation would ban UK businesses from using commodities linked to illegal deforestation, targeting products that account for an estimated 64% of the UK's tropical deforestation footprint. However, it only covers illegal deforestation, excludes smaller businesses, and implementation has been repeatedly delayed with no firm timeline.

The evidence

• The policy commits to introducing forest risk commodities legislation early in the next Parliament to tackle the UK's impact on illegal deforestation internationally. — conservatives.com (manifesto) — “introduce forest risk commodities legislation early in the next Parliament to tackle the UK's impact on illegal deforestation internationally”
• The targeted commodities account for an estimated 64% of the UK's tropical deforestation footprint, with up to 93% of that deforestation potentially being illegal. — resources.trase.earth (media) — “estimated to account for 64% of the UK's tropical deforestation footprint, with up to 93% of this deforestation potentially being illegal”
• The legislation prohibits businesses from using forest risk commodities produced on illegally occupied or used land in the country of origin. — legislation.gov.uk (government) — “prohibits businesses from using "forest risk commodities" (FRCs) and derived products in their UK commercial activities if those commodities were produced on land illegally occupied or used according to local laws in the…”
• The legislation applies only to businesses with global annual turnover exceeding £50 million using over 500 tonnes per year of specified commodities. — bakermckenzie.com (media) — “businesses operating in the UK with a global annual turnover exceeding £50 million and that use over 500 tonnes per year of the specified key forest risk commodities”
• Non-compliance can result in unlimited monetary penalties. — bakermckenzie.com (media) — “Non-compliance can result in an array of civil sanctions, including unlimited monetary penalties”
• Full implementation requires secondary legislation, and this has been delayed with the timeline remaining unclear. — hilldavid.substack.com (media) — “the full implementation of this legislation, which requires secondary legislation, has been delayed and its timeline remains unclear”
• Due diligence requirements are expected to encourage businesses to increase transparency and traceability within supply chains. — bakermckenzie.com (media) — “due diligence requirements are expected to encourage businesses to increase transparency and traceability within their supply chains, leading to more sustainable sourcing practices”
• If fully implemented, the legislation is intended to significantly reduce the UK's global deforestation footprint. — questions-statements.parliament.uk (government) — “By making it illegal for UK businesses to source commodities linked to illegal land-use change, the policy aims to significantly reduce the UK's global deforestation footprint”

Biggest unknown: Whether and when the secondary legislation required to operationalise the scheme will actually be passed, and whether restricting only illegal (not legal) deforestation is sufficient to materially reduce the UK's deforestation footprint.

Our reading: The policy targets a large share of the UK's tropical deforestation footprint — commodities estimated to account for 64% of it, of which up to 93% may already be illegal in producer countries. The mechanism is coherent: prohibiting UK commercial use of illegally sourced commodities, backed by unlimited civil penalties and mandatory due diligence reporting, creates a genuine supply-chain lever on international deforestation. If operationalised, the real-world effect on biodiversity and emissions trajectories could be moderate at the long-term horizon, supporting O6's indicators on emissions trajectory and nature. However, several factors temper confidence. First, the biggest structural gap is that the legislation covers only illegal deforestation; legal deforestation — potentially a large residual driver — remains outside scope, raising the risk that exporting countries weaken domestic protections to remain compliant. Second, the scheme targets only large businesses (£50m+ turnover, 500+ tonnes), leaving smaller actors untouched. Third, and most importantly for direction and confidence: implementation has been repeatedly delayed and the secondary legislation needed to operationalise the regime has no firm timeline. The policy commitment is to introduce the legislation 'early in the next Parliament', but the gap between introducing enabling primary legislation and actual enforcement is significant and already evidenced by past delay. Absent the policy, the UK's supply chains would continue to import commodities linked to illegal deforestation with no systematic due-diligence requirement — so there is genuine additionality if enacted. The long-term direction is 'improves' because the mechanism, if fired at scale, addresses a documented real-world driver of deforestation. Magnitude is 'moderate' rather than 'major' given the legal-only scope and business-size threshold. Confidence is 'low' because the decisive question — whether secondary legislation will be passed promptly and enforced — is unresolved.