Greater urgency needed in due diligence regulations under UK Environment Act

Global Canopy is urging the UK government to show greater ambition and urgency in new regulations designed to tackle tropical deforestation in supply chains.

Addressing tropical deforestation is crucial to help deliver on climate goals. Companies need to be acting as early as possible and across as many key commodities as possible to help drive change on the ground.

Responding to the Department of Food and Rural Affairs’ consultation on implementing provisions on corporate due diligence for forest risk commodities in the UK Environment Act, Global Canopy said it was critical that this covers the key commodities responsible for the UK’s deforestation footprint and comes into force within 12 months.

The consultation proposed a phased approach to including these commodities, with a suggestion that business would be able to act faster if fewer commodities were included in the first phase. Including a maximum of seven commodities would mean it would be impossible to take action within five years, according to the proposal.

But government data¹ show that UK consumption is linked to more than 30,000 hectares of tropical deforestation each year – an area greater than the size of Birmingham – with these seven commodities responsible for an estimated 65% of the UK’s annual deforestation risk – beef, palm oil, soy, maize, coffee, cocoa and rubber.

Even including all of these commodities, the legislation would miss a third of the UK’s footprint.

The largest impact is due to imports of cattle products (including beef, leather and associated products).

Global Canopy said that at a minimum cattle products, palm oil, and soy – the biggest drivers – must be included in the first phase, but limiting cover to these three would cover just half of the overall deforestation footprint.

Cattle	Palm oil	Soy	Maize	Coffee	Cocoa	Rubber
7,372 ha	5,496 ha	3,084 ha	1,809 ha	1,401 ha	679 ha	483 ha

Global Canopy argues that there are significant savings for business in introducing due diligence processes across all commodities because similar traceability and risk assessment and mitigation processes are needed for each. Both the EU and US proposals for similar corporate due diligence on deforestation would come into force within 12 months.

“There is an urgent need to address tropical deforestation across all of the key commodities driving deforestation. Delaying action will mean that UK business will continue to drive deforestation for years to come.”

Helen Bellfield, Global Canopy Policy Director

Global Canopy’s consultation response also proposed that clear requirements for due diligence reporting need to be included in the secondary legislation and argued that reports should be made public, providing valuable information for the financial institutions, as well as allowing greater accountability.

A number of larger retailers already have deforestation-free commitments that go beyond the scope of legality in this regulation and the government’s impact assessment indicates that costs are expected to be extremely low, making it clear that businesses will be able to meet these requirements.

“We have seen that voluntary action over the past decade has not led to sector wide progress and that a regulatory cliff edge is needed to level the playing field and spur action beyond the handful of companies that are making progress. To do this, the regulation needs to cover all companies and not just large companies as currently proposed.”

Helen Bellfield, Global Canopy Policy Director

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¹ Produced by the Joint Nature Conservation Committee (JNCC) and Stockholm Environment Institute