What happened

The Department for Environment, Food and Rural Affairs published the consultation on Wednesday 11 November 2026. It sets out how the government plans to use the powers in Schedule 17 of the Environment Act 2021, which were passed five years ago but never switched on because the detailed regulations were never made. Carbon Pulse first reported the proposals; we have written this from Defra's own consultation document.

The main proposals are:

  • Six commodities, plus timber. The rules would cover products made from oil palm, cattle, soy, rubber, cocoa and coffee, defined by customs (HS) codes and broadly matching the EU list. The existing UK Timber Regulation would be widened to more wood products.
  • A £1 million turnover threshold. Businesses with a global annual turnover above £1 million in their previous financial year would be in scope, however little of a commodity they use. Defra says it does not intend to exempt anyone on volume.
  • Traceability to the farm or forest. Regulated commodities would have to be traceable to the area where they were produced, with geolocation data as evidence. Any risk that they broke local laws would have to be reduced to a "negligible level" before the business uses them.
  • Annual reports and penalties. In-scope businesses would report on their due diligence each year, with some of it published. Defra asks whether the maximum penalty should be a fixed sum, a share of turnover or unlimited.

The document says agricultural expansion causes at least 80 to 90% of permanent forest loss, that 6.7 million hectares of primary tropical forest were lost in 2024, and that UK consumption was estimated to drive 29,000 hectares of deforestation in 2023, the second highest footprint of any European country.

What it means for your business

The threshold is the headline. At £1 million of turnover, these rules would reach well beyond big food manufacturers and supermarkets: a café group buying coffee, a bakery using cocoa and palm oil, a butcher or caterer buying beef, a furniture maker or a tyre wholesaler could all be in scope if the products they handle are on the final list. Retailers and online sellers count too, since the document says the duties apply to online and distance sales.

Defra is also asking whether businesses further down the chain could rely on information passed on by their suppliers, and whether sharing that information between businesses should be a legal requirement. In practice, larger customers would start asking smaller suppliers for origin data, much as they already ask for carbon figures. Nothing changes today: the rules still have to be written, and Defra has not given a start date.

There is a carbon link as well. Land cleared for farming is one of the biggest sources of emissions in food and agricultural supply chains, and those emissions sit in your Scope 3 purchased goods. Knowing which of your purchases contain these commodities, and where they come from, is the same groundwork a better Scope 3 estimate needs.

What to do now

  • List what you buy. Go through your purchase ledger for anything containing oil palm, cattle, soy, rubber, cocoa and coffee or timber, including packaging, ingredients and finished goods, and note which suppliers it comes from.
  • Ask your suppliers what they know. Find out whether they can already say where a commodity was grown. Suppliers selling into the EU or Northern Ireland may be collecting geolocation data for the EU rules already.
  • Respond if it affects you. Defra asks directly whether £1 million is the right threshold and what the rules would cost smaller firms. Responses go through the consultation hub by 17 January 2027.
  • Connect it to your carbon report. Our guide to Scope 3 categories explains where purchased goods sit, and why supplier-specific data beats spend-based averages.