UK Parliament pushes for tougher stance on imported
In a report published on 4 January the UK Parliament’s
Environmental Affairs Committee (EAC), made up of
MPs, claims the intensity of the country's commodity
consumption, when measured by its carbon footprint per
tonne of product consumed, is higher than that of China
and should "serve as a wake-up call to the government".
The world's forests are being put under "enormous
pressure" by the UK's appetite for commodities like soy,
cocoa, palm oil, beef and leather, the EAC report claims.
This should "serve as a wake-up call to the government",
said EAC chair Philip Dunne, who added that the UK's use
is having an "unsustainable impact on the planet".
The EAC’s 66-page report1 focuses on Britain's
contribution to tackling global deforestation. It comes after
ministers announced that UK importers of four
commodities - cattle products (excluding dairy), cocoa,
palm oil and soy - will have to implement due diligence
procedures to avoid products from illegally converted
forest land. This is in addition to pre-existing requirements
on timber traders to follow the requirements of the UK
Timber Regulation (UKTR).
The range of organisations and individuals consulted by
the EAC was narrow and heavily weighted towards civil
society. There is no indication that any tropical forestry or
producer representatives were consulted by the Committee
when preparing the report with all input from the trade and
industry side from domestic UK foresters and associations.
The EAC report notes that it “draws on 55 written
submissions to the inquiry and five public evidence
sessions hearing from 24 witnesses including academics,
environmental NGOs, forestry sector representatives and
Government agencies”. Additional input was “derived
from a virtual roundtable discussion with representatives
from NGOs in countries affected by tropical
deforestation”. No equivalent discussion was organised for
the private sector.
The narrow range of stakeholder input did not deter the
EAC from making far-reaching recommendations. The
UK government, which has adopted a phased approach
and not yet announced when enforcement of the new
deforestation law will begin, is criticised by the
Committee for failing to respond more urgently.
The EAC recommends that the Government’s proposals
for due diligence legislation should include from the outset
all forest risk commodities associated the UK’s
deforestation footprint (soy, palm oil, cocoa, maize, beef
and leather, rubber and coffee).
The EAC is also critical of the fact that the UK law, unlike
the EU Deforestation Regulation (EUDR) only prohibits
the import of products from illegal deforestation.
The EAC observes that “products of legal deforestation
are not currently within scope of the proposed system”.
The Committee calls for the law to be amended to align
with the EUDR and prohibit imports of commodities
“linked to deforestation activity as defined by the UN
Food and Agriculture Organization, whether or not the
activity is permitted by local legislation”.
In support of this recommendation, the EAC reports that
90% of respondents to the UK Government’s earlier
consultation on new laws for forest risk commodities
believed that the proposals should be extended so that it
would be illegal for UK businesses to use any key
commodities related to deforestation in their supply
chains. These respondents included Unilever, Nestle,
Mondelez, and all the UK’s seven largest supermarkets.
On the UKTR, the EAC comments that “current UK
regulation is not sufficient when it comes to limiting non-
sustainable deforestation. It relies too heavily on the laws
in exporting countries and an assumption that that these
laws will incorporate adequate provision for sustainability:
as currently drafted the Regulations take control of the
UK’s impact on sustainable timber production out of the
The EAC therefore recommends that UK Government
bring forward proposals to amend the UKTR so as “not
only to prevent illegally harvested timber being placed on
UK markets but also to require all imported timber to be
There is also criticism of the UK government’s decision to
impose the deforestation regulation only on larger
businesses with a global annual turnover of £50m or more.
Businesses using 500 tonnes or less of each commodity
annually will also be able to apply for an exemption from
the regulations. The UK government says that the
threshold requirements will ensure “that only larger
businesses who can most effectively influence supply
chains” will be within scope. However, the EAC argues
the law should align with the EUDR and UKTR and apply
to all companies irrespective of size.
The EAC’s report also gives insights into UK thinking on
support for supply side measures in tropical countries. The
Committee notes that “To be effective, the Government’s
proposed approach requires the UK to work in partnership
with producer countries and to reinforce (and in some
cases, strengthen) their legal and policy provisions to
We therefore recommend that the proposed demand-side
due diligence system is complemented by Government
initiatives to support and build capacity in producer
countries”. The EAC’s report references the “Fitness
Check” of the EUTR and the FLEGT Regulation
performed in 2021 by the European Commission to
evaluate the implementation and functioning of these two
instruments and to assess whether they were fit for
purpose to halt illegal logging and related trade.
The report notes that the EC Fitness Check recognised
some benefits but ultimately was critical of the FLEGT
programme. However, it also notes that the methodology
and findings of the EU’s Fitness Check were strongly
criticised. Some civil society organisations note genuine
improvements in governance in many VPA countries
falling outside the scope of the Fitness Check and which
were therefore not acknowledged. The Fitness Check
focused primarily on whether a FLEGT license had been
put in place in VPA countries. However, this did not
capture the fundamental improvement to forest
governance achieved in some VPA countries even before
the issue of FLEGT licenses.
The EAC’s report goes on to note that while the EUDR
“will largely replace the FLEGT licensing system and
VPAs when it enters into force”, the structure will be
retained “in recognition of some of the valuable work that
is ongoing under those initiatives”.
According to the report, the new EU legal framework does
recognise the value of FLEGT VPAs “in terms of
enhanced stakeholders’ participation and improved forest
governance.” The report states that, for timber products, a
FLEGT licence will be sufficient to demonstrate that the
timber has been produced in compliance with the laws of
the producer country.
The EAC is less clear on the future of the UK’s own
engagement in VPAs as a tool for cooperation or
partnership with producer countries. It notes that the UK
government first promised a post-implementation review
of FLEGT for publication in 2023 but that no report has
yet been forthcoming.
The EAC notes that at the UN climate summit in 2021 in
Glasgow the UK signed the Global Forest Finance Pledge
committed to developing partnerships in tropical countries
to tackle the causes of deforestation and to “scale up
sustainable economic opportunities”.
Of the total US$12 billion pledged, the UK committed
£1.5 billion (US$1.9 billion) over five years including
£350 million for the program in Indonesia, £200 million
for the LEAF Coalition, and up to £300 million intended
for the Amazon.
However, the report also notes that, in written evidence,
Global Witness and WWF observed that much of the
finance announced by the UK Government at COP26 in
Glasgow had already been committed to programmes prior
to COP26 and it was difficult to ascertain from the little
public information provided how much of the package
announced was ‘additional’ funding.
The EAC suggests that “the UK cannot step off the global
stage in relation to its climate, nature and deforestation
commitments. The Government should make it clear how
the £1.5bn of funding specifically committed to activity to
address deforestation is being spent”.
House of Commons Environmental Audit Committee (2024) The
UK’s contribution to tackling global deforestation. Fourth Report
of Session 2023–24. United Kingdom House of Commons. 4th