UK vs EU: two rulebooks for one product
The EU rule applies from 30 December 2026. The UK is still developing its approach. Here is where the two split.
On this page
- The EU rule is a regulation with a deforestation cut-off date and plot locations. The UK has a legality-based framework in the Environment Act 2021 and says it is still developing its approach.
- Plot locations and proof of legal land use help with both.
- The EU and Great Britain keep separate pesticide residue registers.
If you ship a forest-risk commodity to both Hamburg and Manchester, you meet two different approaches. They share a goal, but one is a detailed regulation that applies from 30 December 2026. The other is a framework whose detail is still to come.13
Who each rule applies to
The EU regulation puts the duty on the operator that places the goods on the EU market. Large operators must comply from 30 December 2026, and micro and small enterprises from 30 June 2027.2 The UK Act applies to businesses it calls regulated persons: non-individual businesses carrying on commercial activities in the UK that meet a turnover condition set in regulations. The commodities covered are also set in regulations.3
The UK government says it is considering its approach and plans to consult. It also says the EU rule will apply in Northern Ireland from the end of 2026.4
| Requirement | European Union | United Kingdom |
|---|---|---|
| Legal basis | Regulation (EU) 2023/1115 | Environment Act 2021, Schedule 17 |
| Plot geolocation | GPS point or polygon for every plot | Not set in the Act. Left to regulations |
| Cut-off date | 31.12.2020 | None in the Act. Legality of land ownership and use |
| Who is covered | Operators placing goods on the EU market | Regulated persons: UK businesses above a turnover condition set in regulations |
Table 1 · Source: regulation texts
What evidence buyers ask for
EU buyers need the location of every plot and proof the land was not deforested after 31 December 2020, plus evidence the goods were produced legally. Under the UK Act, a regulated business must not use a forest risk commodity unless the relevant local laws on land ownership and use were complied with. Proof of legal land use therefore helps with both.13
“Our buyer in Hamburg and our buyer in Manchester asked for different maps of the same farms.”
Where residue limits differ
Food and feed must meet the pesticide maximum residue levels in force where it is placed on the market. Great Britain and the EU each keep their own register, so check the one for your market and your substance.5
One file for both markets
Build one file with plot maps, land titles or permits, and lab results. Then map each item to the rule it satisfies.
EU and UK- Plot GPS coordinates for every supplying farm
- Proof of legal land use, such as titles or permits
- Evidence of no deforestation after 31.12.2020
- Lab results against the residue levels of the market you ship to
Sources
- Regulation (EU) 2023/1115, Articles 1 and 3 (opens in a new tab)
- European Commission, Access2Markets: delay until December 2026 (Regulation (EU) 2025/2650) (opens in a new tab)Reviewed as of 23.10.2026
- Environment Act 2021, Schedule 17 (use of forest risk commodities in commercial activity) (opens in a new tab)Reviewed as of 23.10.2026
- GOV.UK, The UK’s approach to deforestation regulations (opens in a new tab)Reviewed as of 23.10.2026
- GOV.UK, Food and drink businesses: working with the EU (pesticide MRLs) (opens in a new tab)Reviewed as of 23.10.2026
