EUDR and the UK: Two Regimes, One Supply Chain - What Northern Ireland and Great Britain Mean for Your Business

If you trade in forest-risk commodities and operate anywhere in the UK, you are now navigating two different deforestation regimes - and the dividing line runs between Great Britain and Northern Ireland.

That is not a drafting quirk. It is a deliberate consequence of the Windsor Framework, and it creates three distinct compliance situations depending on where you place goods on the market. This guide explains the split, what each situation requires, and what you should be doing right now.

---

The split explained: why the UK has two regimes

The EU's regulation on deforestation-free products (EUDR, Regulation (EU) 2023/1115) will apply in Northern Ireland, replacing the European Timber Regulation (EUTR). EUDR will not apply in Great Britain (England, Scotland and Wales).

The reason is straightforward. To maintain Northern Ireland's unique dual market access to both the UK Internal Market and the EU Single Market, the EUDR applies in Northern Ireland in phases starting 30 December 2026. Great Britain, by contrast, is treated as a third country under the EUDR - meaning the regulation does not apply there as domestic law.

That does not mean Great Britain escapes deforestation rules entirely. On 23 June 2026, the UK Government published a written statement (HCWS137) confirming plans to introduce mandatory due diligence requirements for businesses in Great Britain, using powers under Schedule 17 of the Environment Act 2021, alongside legislation to strengthen the existing UK Timber Regulation. The GB regime is announced policy, not yet law. A consultation is expected later in 2026, with legislation targeted for 2027.

---

The comparison at a glance

---

Situation 1: You place goods on the market in Northern Ireland (or move goods from GB to NI)

This is the most time-critical situation. If you are an operator or trader who first places in-scope products on the Northern Ireland market - or exports from Northern Ireland - you are subject to the full EUDR from the dates below.

The deadlines:

• Large and medium operators and traders: 30 December 2026
• Micro and small operators and traders: 30 June 2027 (with an earlier 30 December 2026 date for wood products currently regulated under the EU Timber Regulation)

What full EUDR compliance means in practice:

• Geolocation data. Products in your supply chain must be traceable to the plot of land where the commodity was produced. For plots of 4 hectares or more, polygon-level GeoJSON data is required.
• Deforestation-free and legally produced. The commodity must not have been produced on land deforested after 31 December 2020, and must comply with the laws of the country of production - including land tenure, environmental, and labour law.
• Due Diligence Statement (DDS). Operators must submit a DDS to the EUDR Information System before placing goods on the market. This generates a unique reference number that must be passed down the supply chain to downstream businesses. Micro and small primary operators (MSPOs) submit a one-off simplified declaration instead.
• Registration. Non-SME downstream operators must register on the EUDR Information System.
• Record-keeping. All documentation - geolocation files, risk assessments, supplier records - must be retained for a minimum of five years.
• Annual public reporting. Non-MSPO operators must annually report publicly on their due diligence system.

Who enforces it? Two competent authorities have been designated for Northern Ireland: the Office for Product Safety and Standards (OPSS) for rubber and wood products, and the Department of Agriculture, Environment and Rural Affairs (DAERA) for cattle, cocoa, coffee, palm oil, and soy.

One practical note on GB-to-NI movements. If a product has already been on the EU or Northern Ireland market before it entered the Great Britain market, you do not need to submit a new DDS to move it back into Northern Ireland. The UK Government has also indicated that businesses sending eligible products from GB to a consumer in NI may be able to use the UK Carrier Scheme (UKC) in certain circumstances - further technical guidance is expected.

One advantage for UK-sourced goods. The UK is classified as a low-risk country under the EUDR's country benchmarking system. This means operators can benefit from simplified due diligence requirements for goods produced in GB and exported to the EU or moved to Northern Ireland - you do not need to undertake the full risk mitigation steps required for standard or high-risk country sourcing.

---

Situation 2: You export from Great Britain to the EU

If your business is based in Great Britain and sells to EU customers, the EUDR does not apply to you directly as domestic law. But it applies to your EU customer - and they cannot submit a valid DDS without data from you.

This is the "supplier in someone else's due diligence" problem, and it is already live.

Under the EUDR, the obligation to submit a DDS falls on the operator who first places the product on the EU market. Without a valid DDS reference number, shipments are legally blocked at EU customs. That means your EU buyer cannot import your goods unless you have provided them with the geolocation data, supplier information, and legal compliance evidence they need to complete their own due diligence.

What your EU customers will need from you:

• Plot-level geolocation coordinates for the production origin of in-scope commodities
• Evidence that the land was not deforested after 31 December 2020
• Documentation of legal production (land tenure, permits, applicable local laws)
• Supplier and HS code details

Because the UK is classified as a low-risk country, your EU customer's due diligence burden is lighter - but it is not zero. They still need your geolocation data and must be able to demonstrate a negligible risk conclusion.

The practical implication: if you have EU customers buying cattle products, cocoa, coffee, palm oil, rubber, soy, or wood from you, they are asking - or will shortly ask - for EUDR-grade supply chain data. Businesses that cannot provide it risk losing those contracts. The time to build that data infrastructure is now, not after your first lost order.

---

Situation 3: You only sell in Great Britain

If your entire market is Great Britain and you have no NI or EU exposure, you are not subject to the EUDR. But the GB regime is coming - and the direction of travel is clear enough to act on now.

What the government has announced (but not yet legislated):

• The legal basis is Schedule 17 of the Environment Act 2021, which provides powers for a "forest risk commodity" regime.
• The proposed scope covers businesses in Great Britain with annual turnover over £1 million that use forest risk commodities and wood products.
• The proposed commodities are the same core set as the EUDR: cattle, cocoa, palm oil, rubber, soy, and wood products.
• Businesses would need to establish a due diligence system, collect geolocation data on the origin of products, and report on their activity.
• A consultation is expected later in 2026. Legislation is targeted for 2027.

The key difference in standard - and why it matters:

The announced GB approach is built on an "illegal deforestation" framing: businesses would need to verify that commodities comply with the relevant laws of the country of production. The EUDR goes further - it covers all deforestation after the 31 December 2020 cut-off, regardless of whether that deforestation was legal under local law, and additionally requires legal production. The government has indicated it may move toward a deforestation-free standard over time, but the initial GB regime as announced is narrower in this respect.

This distinction matters for how you frame your due diligence system. If you build to the EUDR standard now, you will exceed the announced GB requirement and be well-positioned if the standard is raised. If you build only to the announced GB standard, you may need to upgrade later - and you will not have the data your EU customers need if you ever start exporting.

Why waiting is expensive:

The hardest part of EUDR-style compliance is not the paperwork - it is collecting geolocation data from suppliers who have never been asked for it before. That takes time: supplier outreach, data validation, chasing non-responders, and building the internal processes to keep it current. Every month you delay is a month less to build that infrastructure before the GB legislation lands.

The government has been explicit that it wants the information GB businesses must hold to be broadly the same as what is needed for a due diligence statement when exporting to the EU or moving goods to Northern Ireland. Starting that data collection now means you build it once, not twice.

---

Your situation in 60 seconds

Use the tool below to identify which of the three situations applies to your business and get a summary of your immediate priorities.

---

What to do now, by situation

If you are in Situation 1 (NI market):

1. Register on the EUDR Information System if you have not already done so.
2. Map every in-scope product in your supply chain and identify your role (operator, MSPO, downstream trader).
3. Begin geolocation data collection from Tier-1 suppliers - this is the longest lead-time item.
4. Confirm your competent authority (OPSS or DAERA) and monitor their enforcement guidance.
5. Check whether the UK Carrier Scheme applies to any of your GB-to-NI movements.

If you are in Situation 2 (GB exporter to EU):

1. Identify which of your products are in scope under EUDR Annex I - note the July 2026 Delegated Act updated the product list.
2. Contact your EU customers now to understand exactly what data they need from you and by when.
3. Build a geolocation data request process for your suppliers.
4. Remember: the UK's low-risk country classification simplifies your EU customers' due diligence, but does not eliminate their need for your origin data.

If you are in Situation 3 (GB-only):

1. Check whether your turnover and commodity use puts you within the proposed GB scope.
2. Start geolocation data collection from suppliers - the data you collect now will serve both the GB regime and any future EU export ambitions.
3. Monitor the GB consultation (expected late 2026) and respond to it - the detail of the regime is still being shaped.
4. Consider building to the EUDR standard rather than the announced (narrower) GB standard, to avoid having to upgrade later.

---

This article covers the position as of August 2026. The GB deforestation regime is announced policy, not yet law - the consultation and subsequent legislation may change the detail. Always verify against the official sources linked throughout and seek qualified legal advice for decisions specific to your business.