Four years ago today Royal Assent was given to the first major piece of UK environmental legislation since exiting the European Union (EU): the Environment Act. While most of the law is about managing and protecting the UK’s own environment - no surprises there - one section towards the end ostensibly attempts to curb complicity in the destruction of other countries’s environments by regulating “forest risk commodities” entering the UK. Think beef, soy, palm oil, cocoa. . . that sort of thing.
But that section of the Act hasn’t ever come into law because the secondary legislation required to enact it hasn’t been introduced. That almost happened last year in May, but the General Election called by then Prime Minister Rishi Sunak appears to have derailed things.
Of course, no one in the UK government should need to be told why forests are so important or how bad things are around the world, especially with the United Nations (UN) climate change conference, “COP30”, starting tomorrow in Belém, the capital of Brazil’s Pará state. Just look at all the reports that keep coming out, week after week. Last month alone saw a coalition of civil society organisations and researchers release their annual “Forest Declaration Assessment” (FDA), and then the very same day another coalition published its “Global Tipping Points Report 2025.” Less than 24 hours later, the NGO Global Witness issued a report on the banks and other financial institutions profiting from some of this destruction, and then a week after that the UN Food and Agriculture Organisation released its 2025 “Global Forest Resources Assessment.”
And that’s just the reports that were published - what about those that didn’t make it that far? According to both The Times and The Guardian last month, one was apparently so distressing it was held back.
“No 10 conceals year-long study of risks to UK if ecosystems fail,” was the headline of a Times article, with the first sentence reading: “Downing Street has blocked the publication of a report warning the collapse of tropical rainforests could push up food prices in British supermarkets.”
Over in The Guardian it was described as a “powerful report by the UK’s intelligence chiefs” warning “UK’s national security is under severe threat from the climate crisis and the looming collapse of vital natural ecosystems, with food shortages and economic disaster potentially just years away.”
The FDA in particular makes for grim reading. Arguably the key takeaway: 8.1 million hectares of forest were razed in 2024 - 6.7 million being humid tropical primary forest - meaning the world is a long, long way off-track from achieving net zero deforestation by 2030, as promised by international commitments like the 2021 Glasgow Leaders’ Declaration on Forests and Land Use.
Other main takeaways from the FDA: the biggest deforestation driver is “permanent agriculture”, “governments are not living up to ambitious forest commitments”, and “corporate deforestation promises still lag.” Perhaps most shocking: that in recent years an average of only US$5.7 billion of international public finance has gone to forest protection and restoration, while the “average annual finance directed towards agricultural subsidies linked to output or the unconstrained use of inputs such as fertilizer or fuel” are estimated at US$409 billion.
Rhett Ayers Butler, founder of environmental news outlet Mongabay, calls that difference “staggering.” “Subsidies for industrial agriculture outweigh global forest finance by hundreds to one,” he wrote in an article this week. “Until that ratio shifts, conservation will remain a niche enterprise trying to compete with some of the most profitable destruction in human history.”
Amidst all this Bad News, some MPs have been pushing the UK to take action. For example, just this week the chairman of the Environmental Audit Committee, Toby Perkins, wrote to the Energy Security and Net Zero Secretary Ed Miliband calling “once more on the Government to bring forward secondary legislation on forest risk commodities under Schedule 17 to the Environment Act without delay.”
“Witnesses at our evidence session [on 22 October] stressed the importance of bringing forward this legislation as soon as possible, as well as considering the adverse impacts on businesses operating in multiple jurisdictions of diverging approaches to such regulations, particularly in light of the EU Deforestation Regulation [due to take effect next month],” Perkins wrote. “We also urge the Government to work with EU to ensure that this legislation is as compatible as possible with the EU Deforestation Regulation.”
Prior to that, Perkins was one of 18 MPs who spoke at a debate in mid-October held in Westminster Hall on “Food System Transformation” when deforestation was mentioned numerous times, although only one of those MPs, Barry Gardiner, referred specifically to the pending forest risk commodities legislation. Gardiner believes the regulations must be strengthened - e.g. so they apply to all deforestation, more commodities and the UK’s financial sector - and brought to Parliament as soon as possible.
“[This] is also about the financial flows facilitated through the City of London,” Gardiner told the debate. “HSBC has provided credit lines amounting to £1.9 billion to forest risk commodities such as JBS, the world’s largest meat company, which has a record of corruption and forest destruction in Brazil. . . That flies in the face of HSBC’s 2017 commitment not to provide services to customers either directly or indirectly involved in deforestation. That is why we need to implement schedule 17 to the Environment Act 2021, which still has not been implemented, in order to ensure that we are not financing deforestation.”
Gardiner also raised this issue at the EAC’s 22 October evidence session when it heard from Brazil’s Ambassador to the UK, Antonio De Aguiar Patriota. In response to Gardiner’s question about Schedule 17 and whether Brazil’s President, Luiz Inácio Lula da Silva, supports the introduction into the UK of “supply chain legislation to avoid the transformation of forests into land for agricultural production”, the Ambassador said it raised “serious methodological questions” and was “something of questionable wisdom.”
Earlier in the year, in July, the EAC’s Perkins also wrote to the UK’s Environment Secretary Steve Reed urging “the Government to bring forward this secondary legislation [on forest risk commodities] as soon as possible.”
“Delays in bringing forward this legislation makes the COP15 agreement to halt and reverse biodiversity loss, and the UK’s commitment to ending deforestation and forest degradation by 2030, harder to achieve,” Perkins told Reed, who has since been replaced by Emma Reynolds. “However, it also leaves businesses with uncertainty and will leave them with less time to prepare and comply with the regime.”
In reply, Minister for Nature Mary Creagh said she shared Perkins’s “concern about the impact of UK supply chains on deforestation and remain[s] committed to working with international partners to achieve our commitment to halt and reverse global deforestation by 2030”, but that the “approach enshrined in Schedule 17 of the Environment Act remains under consideration, although no options have been ruled in or out at this stage. Our decision-making must also consider the implications of the EU Deforestation Regulation on UK businesses who trade with the EU, as well as consideration of our approach in Northern Ireland.”
This week UK Prime Minister Keir Starmer told a pre-COP30 Heads of State summit in Belém that the UK was “all in” on tackling the climate crisis, according to The Guardian. But if the UK is “all in”, wouldn’t it be making much more effort to reduce its role in global deforestation, a major contributor to carbon emissions?
“We recognise the need to take action to ensure that UK consumption of forest risk commodities is not driving deforestation,” was all the Department for Environment, Food & Rural Affairs (DEFRA) was able to say when asked for comment about the pending Environment Act regulations. “We will set out the next steps on this in due course.”