Two deforestation regimes are now heading for the same supply chains — the EU’s EUDR and the UK deforestation regulation — and suppliers are starting to ask which one to prepare for.
Where each regime stands
The EU Deforestation Regulation applies from 30 December 2026 for large and medium operators, and 30 June 2027 for small and micro operators. It has been postponed twice, but the Commission confirmed in May 2026 that the December date stands.
The UK regime — the Forest Risk Commodity provisions under Schedule 17 of the Environment Act 2021 — has moved much more slowly. In June 2026, DEFRA confirmed it would bring the rules forward, covering businesses in Great Britain with an annual turnover above £1 million. A consultation is expected later in 2026, with legislation likely in 2027.
So the EU deadline is roughly four months away. The UK one is probably eighteen months to two years out, and its detail is not yet settled.
The two ask for different things
This is where suppliers get caught, because the regimes sound similar and are not.
EUDR asks two separate questions. Was this material produced legally under the laws of the producing country? And was the land it came from free of deforestation after 31 December 2020? Material has to pass both tests. Legality alone is not enough — a perfectly legal harvest on land cleared in 2022 produces non-compliant material.
To answer the second question, EUDR requires plot-level geolocation: GPS coordinates for every plot, and full polygon boundaries for any plot above four hectares. That is how anyone checks the land against satellite records for the cut-off date.
The UK regime has been moving toward EUDR, not away from it. DEFRA’s June 2026 policy paper confirmed it will require a legality check and a due diligence system with annual reporting — but it also signalled the rules will extend to legal deforestation, not just illegal harvesting, closing what had been the main gap with EUDR. Two details are still genuinely unsettled: whether there will be a fixed cut-off date, and whether geolocation data will be required in the same way EUDR requires it. DEFRA’s forthcoming consultation is expected to confirm both.
One difference is settled either way: EUDR has no turnover threshold — it catches operators of any size, and individuals. The UK regime starts at £1 million turnover. The commodity list, though, is no longer a real difference — DEFRA’s June 2026 announcement aligned the UK scope with EUDR’s: wood, cattle, cocoa, coffee, palm oil, rubber, and soy.
Why this means you build once
Set the two side by side and the relationship becomes obvious.
Everything the UK regime is confirmed to ask for, EUDR also asks for. Legality evidence, a documented due diligence system, records you can produce on request — all of that sits inside EUDR’s requirements. EUDR also carries a deforestation-free test with a fixed cut-off date and plot-level geolocation — both of which the UK is still deciding whether to adopt in the same form.
So a supplier who builds to EUDR’s standard will satisfy a UK legality test comfortably. A supplier who builds only to the UK standard will not be able to supply the EU, and will have to do the harder work later anyway — under more time pressure, and probably while a buyer waits.
For anyone selling into both markets, that argues for doing the work once, at the higher bar.
There is a caveat worth stating plainly: the UK rules are not final. The consultation has not happened. It is possible the eventual regime lands closer to EUDR than the June announcement suggested — the government said it intends to mirror the EU approach, and pressure to align is real. If that happens, suppliers who built to the EU standard lose nothing. Suppliers who built to the lower one lose a year.
Where PEFC and FSC certification fit
Neither regime is satisfied by a certificate alone, and it is worth being blunt about that because the opposite is being implied across the market.
Chain of custody certification proves your material handling, claims and record keeping are controlled and independently audited. That is genuinely valuable, and it is the operational spine that this data collection sits on. But no EU operator can file a compliant Due Diligence Statement by pointing at your certificate, and no UK business will be able to discharge its obligation that way either.
Both schemes have built EUDR routes on top of their existing standards — PEFC’s EUDR Due Diligence System module, ST 2002-1:2024, and FSC’s Regulatory Module, marketed as “FSC Aligned for EUDR”. Both are voluntary add-ons requiring additional audit. Neither is automatic, and neither removes your buyer’s obligation.
What they give you is an audited, documented process a buyer can rely on, rather than a spreadsheet you assembled under pressure.
What suppliers should do now
Build your traceability to the EU standard. Plot-level geolocation, polygons above four hectares, verification against the 31 December 2020 cut-off. It is the harder specification and it covers both regimes.
Ask your EU customers what they need, in writing. Their requirements will be more specific than the regulation, and their timeline will be earlier than the deadline — they need to test your data before their own liability starts.
Watch the UK deforestation regulation consultation. If you supply British customers as well, the detail that emerges later this year determines whether the two regimes converge. Either way, EUDR readiness is the position you want to be holding when it lands.
Start with geolocation. It is the part that takes longest, and it cannot be accelerated. No consultant, platform or certificate produces coordinates for plots nobody has visited. That work is fieldwork, and it runs in months rather than weeks.
Suppliers who begin now have time to do this properly, test it on a real consignment, and fix what breaks. Suppliers who begin in November will be assembling evidence under pressure while their buyers decide who to keep for 2027.
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Where to start
If you are not sure whether your current records would satisfy either regime, a readiness review will tell you. We look at your supply chain, your existing certification and your documentation, and set out plainly what is missing and how long it will take to close.
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Paul Wilson is a PEFC and FSC Chain of Custody specialist with experience across Indonesia, Myanmar, Cambodia, Vietnam, Laos, Solomon Islands, and wider Asia-Pacific supply chains. He supports timber manufacturers, exporters, and wood-product businesses with practical certification systems, internal audits, and due diligence systems.