Members of the NGO forest coalition have submitted their response to the UK government review on Responsible Business Conduct (RBC). In 2022 alone the UK’s consumption of agricultural commodities was associated with more than 35,000 hectares of deforestation. So in our submission, Friends of the Earth, Earthsight, Global Witness, the Environmental Investigation Agency, Mighty Earth, Global Canopy and WWF have made it clear that effective laws to prevent UK consumption driving global deforestation and human rights abuses are a priority.
Responsible business conduct is key to halting and reversing deforestation
In March 2025, Global Witness released research showing that UK imports in 2024 alone were linked to deforestation the size of a major city like Liverpool. The UK is part of the deforestation crisis and the government could have saved an area larger than the New Forest if it had enacted effective laws to prevent UK consumption driving global deforestation and human rights abuses.
With Schedule 17 of the Environment Act 2021 already in place, the government has the opportunity to swiftly finalise the long-awaited secondary regulations needed to implement the law. In doing this, the government must ensure that the due diligence regulations are genuinely effective, using a regulatory structure that requires companies to conduct comprehensive due diligence and ensures robust enforcement and reporting requirements.
Nature is critical to the economy, with the OECD noting that “over half of the world’s GDP is moderately or highly dependent on nature and its services,” emphasising the need for common standards to embed due diligence into “core business processes.” The OECD-FAO Guidance for Responsible Agricultural Supply Chains highlights that standards are needed to “ensure that [agriculture supply chain] activities do not lead to adverse impacts and contribute to sustainable development”. But currently a significant regulatory gap persists in the UK.
Deforestation due diligence is an area where immediate legislative clarity is essential. In the current vacuum, businesses are being placed at risk while forests continue to be lost. While many companies are willing and ready to act, the absence of legislation distorts the level playing field, preventing concerted action and urgently-needed progress. Introducing regulation would accelerate the adoption of responsible business practices by compelling major actors across global supply chains to deliver the transparency and verifiability that businesses need to ensure sustainable sourcing of forest-risk commodities.
In April 2025, Global Witness and WWF UK polled the UK public, finding widespread support for the trade legislation across political and age groups, with the findings mentioned in UK parliament as a rationale for advancing the law. But it also has the support of many businesses across the UK and Europe. Nine major retailers, including Morrisons, Tesco and Co-Op, signed a WWF-UK open letter urging the implementation of UK deforestation due diligence, which has otherwise “left UK businesses in limbo and uncertain and unable to fully respond to these challenges”. Meanwhile, Nestle, Mars Wrigley, Ferrero and Tony’s Cholocolonely (amongst others) also signed an open letter against the proposed delay to the EUDR. In both cases, businesses emphasise that the absence and uncertainty around enforceable regulation are already driving up operational costs. WWF’s UK Retailers Basket report and traders assessment of what is known of UK importers and supply, continues to highlight the barriers which the private sector cannot address without regulation tools to increase transparency. This follows years of private sector engagement, to inform what effective due diligence could be achieved to address and protect the natural resources we all rely on in line with their own, nature, climate and wider political and economic goals.
Evidence of harms linked to UK companies
In our submission to the Department of Business and Trade we highlighted multiple examples of harms linked to UK companies that are simply not compatible with Responsible Business Conduct.
- Evidence compiled by Friends of the Earth/WALHI from March 2022 and June 2024 looked into palm oil plantations owned by Agra Astro Lestari, Indonesia’s second largest palm oil supplier, whose parent company is a subsidiary of Jardine Matheson, owned by the Scottish Keswick family. It led to UN special rapporteurs raising serious concerns about allegations of human rights and environmental abuses by AAL.
- Earthsight’s report The Hidden Price of Luxury linked the supply chains of luxury fashion brand Coach to illegal cattle ranching in the Amazon rainforest. The UK is one of Coach’s fastest growing markets. Another Earthsight report – Grand Theft Chaco – revealed the links between the leather used in cars made by Jaguar Land Rover and the illegal destruction of the lands belonging to some of the last uncontacted peoples in the Americas.
- Mighty Earth’s Soy and Cattle Deforestation tracker exposes the connection between major global meatpackers and soy traders, and deforestation in Brazil. In the Scorecard companies are scored against how they respond to deforestation in their supply chains and most of these companies will have links through to UK supply chains. Investigative report by Mighty Earth show Tesco and other UK supermarkets linked to illegal deforestation and food company Moy Park and its customers including McDonalds and KFC linked to deforestation contaminated supply.
- Recent investigations have exposed major international brands linked to illegal timber supply chains. The Environmental Investigation Agency (EIA) uncovered that yacht company Sunseeker imported Myanmar teak tied to the military junta, despite repeated warnings. Another EIA report UK firm Tradelink Wood Products and its Brazilian subsidiary Tradelink Madeiras are linked to illegal timber supply chains from Brazil. Earthsight in 2021 revealed IKEA sourced wood from suppliers implicated in illegal logging in Siberian forests, including FSC-certified areas.These cases underscore the urgent need for stronger due diligence regulations and accountability in global timber trade.
Global Witness has conducted extensive research showing UK financial institutions are complicit in bankrolling companies’ supply chains including “The Cerrado crisis: Brazil’s deforestation frontline.” The investigation shows UK banks and investment outfits such as Barclays and HSBC, as well as ING Group, Merrill Lynch, and Santander, are contributing to the vast deforestation of climate critical forests in Brazil by collectively underwriting billions of dollars’ worth of bonds in recent years to Brazil’s 3 largest meatpackers.
Concerns with the review process
We also raised our concerns over the lack of transparency of the review process. There was a lack of publicly available terms of reference, timeline, clarity over civil society and rightsholders’ and affected peoples’ engagement and commitment to publish the final review and recommendations. We would urge the team to address this.
There have also been mixed messages over the extent to which the review will address environmental harms alongside modern slavery and other human rights abuses, even though the two are often interlinked.
The need for UK action to address deforestation risks in supply chains is urgent. The RBC review is an important opportunity to consider wide-ranging legislation to address human rights and environmental harms in the supply chains of UK businesses. However, this process should not prevent the UK government from implementing its existing commitments – including to implement Schedule 17 of the Environment Act. All that this deforestation due diligence obligation requires is compliance with the law (the Environment Act covers only illegal deforestation), which should be the bare minimum for UK businesses. Responsible Business Conduct is key to addressing this.
NGO Forest Coalition 