The Government’s proposal to introduce a due diligence requirement on business is welcome as we recognise that the private sector has a critical role in addressing global deforestation. We are fully supportive of the government’s intention to develop a coordinated strategy to set a level playing field where sustainable commodities are the norm throughout the UK and beyond. To that end, we encourage the Government to go further in the proposed Environment Bill to ensure that this opportunity establishes an effective, workable, and cost-effective framework for halting all forms of deforestation.

We respectfully ask that the Government consider the following as it moves forward with this process:

1. Align the definition of deforestation free with what is necessary to achieve Net Zero... Restricting action to illegal deforestation only would not achieve halting the loss of these natural ecosystems, especially when producing country governments have discretion to decide what is legal or have inadequate enforcement mechanisms, and local land title and clearance records can be unreliable or absent. This is particularly evident when in some landscapes 95% of deforestation has been illegal.
2. Adopt thresholds that reflect the scale influence of the company... [T]his needs to be based on the volume of material and not the size of the company as well as clearly capturing consumer goods manufactured overseasincluding these forest commodities...
3. Facilitate an enabling environment for our companies to act...

[W]e applaud the effort of the Government to bring forward legislation that will create a level playing field. This is a step forward, but it’s not currently envisioned to be enough to halt deforestation and we encourage the Government to go further to embrace requirements that will address this issue.