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Don’t buy into deforestation law delays

03 November 2025

The European Commission wants to delay EUDR due to IT issues, but food businesses can’t afford to switch off from ensuring they have sustainable supply chains.

This article was originally prepared by David Burrows, together with Footprint Media Group and is also available here.

UK national security is under severe threat from the climate crisis and the looming collapse of vital natural ecosystems, like the Amazon rainforest, according to UK intelligence chiefs.

However, the official publication of their warnings has been blocked by Number 10, according to reports. The joint intelligence committee’s “hard-hitting” analysis was due to be published at the start of October, according to The Guardian, but has been “halted”. 

“This is a very stark warning,” a source familiar with the contents told the paper. “It is very clear that the impacts on national security are very worrying.” The Times said the committee will warn that the loss of the Amazon ecosystem could drive up food inflation and lead to mass migration, but has been “blocked” from doing so by Downing Street.

Some commentators suggested the UK Government is not willing to face the issues. Others criticised ministers for focusing solely on carbon emissions, rather than tackling the intertwined crises facing nature and climate. The issue of deforestation seems to have dropped off the radar.

There is a similar story across the Channel, where the European Commission has proposed delaying its anti-deforestation law for the second year running. The flagship environmental policy, EUDR, is designed to force companies to stop using commodities, including palm oil, coffee, cocoa, soya and beef, that are produced on deforested land. Many businesses have complained the reporting requirements are far too arduous, and some member states tend to agree.

NGOs and the large businesses who have invested to prepare for the laws are not happy. “We find it astonishing that the EU would not have the resources and capability to build and operate the infrastructure required for the functioning of the EUDR,” reads an open letter, dated October 7th, and signed by NGOs including Greenpeace, WWF, Fern, Global Witness, Forest Peoples Programme, the Environmental Investigation Agency, as well as law firm ClientEarth.

They called on the Commission’s president, vice presidents and commissioners, to “ensure that this landmark law is implemented in its entirety, as foreseen, on December 30th 2025”.

The EUDR was adopted, as part of the European Green Deal, to fulfil the EU’s commitment to halt deforestation driven by European consumption. A new delay in the application of this law would have disastrous consequences, said the NGOs.

Some of the major food companies affected by the rules agree. and issued their own letter, alongside a cohort of other NGOs, to the EU executive in October, warning that further delay will “undermine industry trust in Europe’s regulatory commitments, create considerable uncertainty and compliance costs for businesses, and put forests worldwide at risk”.

The businesses also outlined how they have been actively preparing and investing “in good faith that the European legislative framework and timeline were reliable”.

Right side of the law

Leading lawmakers in the European Parliament, said the Commission must resolve the technical problems relating to EUDR and not, as some fear, reopen the regulation.

Reopening the text would give conservatives in the Parliament another opportunity to try and water down the EUDR as a whole, reported Ends Europe, last week. “The EPP and the far right pushed through far-reaching amendments to Parliament’s formal stance on the previous delay proposal in a narrow and chaotic vote last year. But those changes were blocked by member states in trilogue,” according to the European green policy website.

EU rules, especially those relating to environmental protection and progress which are currently under pressure across Europe, and the shadow cast by the cost of living crisis, are certainly subject to shifts these days. But whether they can be replied upon to be rolled out to rigid timeframes or not, the food industry can’t switch off.

A number of businesses is impacted by the EUDR rules, which have already been postponed once (a year-long delay was agreed in December, pushing back implementation to this coming December for large businesses and July 2026 for smaller ones). Whilst some firms are “completely on top of this”, while others “have just come across it”.

The EU reporting requirements under EUDR involve considerable amounts of detail (partly explaining why there are concerns about the ability of IT systems to cope with it all). Simply sourcing ‘certified sustainable products’ is not enough, for instance.

Indeed, the due diligence statement that companies must submit to the EU system to prove their products are deforestation-free must include ‘country of production and the geolocation of all plots of land where the relevant commodities were produced’. This is not the time for companies to slow down, and those that have just realised they need to comply must quickly catch up in the extra 12 months they might now have.

UK ‘in limbo’

And what about the UK situation?

EUDR will affect many UK food businesses, and not just in terms of reporting requirements. Compliant commodities are reportedly in short supply and attracting premiums already, for example.

There are also plans to introduce a similar law in the UK to prevent companies from using commodities linked to deforestation: the Environment Act 2021 gave ministers the power to make it mandatory for large companies to carry out due diligence checks to ensure there is no illegal deforestation in their supply chains for forest-risk commodities such as soy, beef and palm oil.

Four years on, successive governments have failed to enact the secondary legislation needed to put the deforestation provisions into effect. Food retailers said earlier this year that they had been left “in limbo” by the UK government.

In July, the Environmental Audit Committee (EAC) asked the Government for an update but what appeared to be a priority for the previous Conservative government has dropped off the agenda under Labour.

Food production is the leading driver of deforestation – an issue the food sector has struggled to get to grips with following decades of voluntary agreements – which is why the UK and EU have reached for the stick. Whether they do so now or in 12 months’ time, switching off for now would be folly.

Indeed, this is not just about following the rules and reporting. This is about supply chain transparency and ensuring resilience for responsibly-sourced ingredients.

If you have any questions on the above and how it may impact your business, please contact Dominic Watkins or Kirsty Poots.

Further Reading