Businesses moving certain goods into or out of Northern Ireland will need to prepare for new deforestation due diligence requirements, following confirmation that the EU Regulations on Deforestation-free Products (EUDR) will apply in Northern Ireland from the end of 2026.
The UK Government has also announced plans to strengthen deforestation regulations in Great Britain.
While the detail is still to be consulted on, the intention is to create a broadly consistent approach across the UK internal market, while recognising Northern Ireland’s continued access to the EU single market.
What is changing?
The EUDR is designed to reduce the contribution of global supply chains to deforestation and forest degradation. It applies to a range of commodities linked to deforestation risk, including cattle, cocoa, coffee, palm oil, rubber, soya and wood, as well as certain products derived from those commodities.
For businesses placing relevant goods on the EU or Northern Ireland market, or exporting them from Northern Ireland, the rules may require evidence that products are deforestation-free and have been produced in line with the laws of the country of production.
In practice, this is likely to mean reviewing supply chains, collecting product and original information, carrying out due diligence and, where required, submitting a Due Diligence Statement through the European Commission’s EUDR Information System. Once validated, that statement generates a unique reference number which may need to be included ion customs information provided to HMRC.
When will the rules apply?
The timetable depends on the size of the business and the goods being traded. Large and medium-sized businesses, together with micro and small primary operators already subject to the EU Timber Regulation, are expected to come within scope from 30 December 2026.
Other micro and small primary operators are expected to follow from 30 June 2027. Certain newly added palm oil-derived products, including specified soap and hygiene products, together and soluble coffee products, are expected to follow from 30 December 2027.
What about Great Britain?
The EUDR itself will not apply in Great Britain. However, the Government has said it intends to introduce a mandatory due diligence framework for businesses in Great Britain with annual turnover above £1 million that use forest-risk commodities and wood products.
The aim is to build on the timber due diligence framework that has been in place since 2013 and to ensure that goods are produced in compliance with relevant local laws. The Government is expected to consult businesses, civil society and international partners on the detail of the proposed Great Britain policy.
What should businesses do now?
Businesses that move, sell or export affected products should start by checking whether any goods they trade fall within EUDR scope. This should include reviewing commodity codes, product descriptions and supplier information, particularly where goods contain or are made suing cattle, cocoa, coffee, palm oil rubber, soya or wood.
It will also be important to speak to suppliers early. Businesses may need to obtain geolocation data, production information and evidence that goods were produced legally and without contributing to deforestation. This information may not be readily available, so preparation should not be left until the implementation dates are close.
Where a Due Diligence Statement is required, businesses should also understand how this will interact with their customs processes. HMRC has made clear that the DDS sits alongside existing customs requirements. It does not replace customs declarations or change the customs route available for a movement.
The rules are still developing, so businesses with complex supply chains, particularly those trading with Northern Ireland or the EU, should use the coming months to map affected products, review supplier due diligence and identify any gaps in the information they hold.
If your business is unsure whether the EUDR or future Great Britain deforestation rules could apply, our team can help you assess the potential impact and prepare for the next stage of implementation.
