Defra has published a summary of responses to "Tackling illegal deforestation in UK supply chains" and received 16,838 total responses to the consultation. However, 262 were identical and received through a Global Witness
campaign, 16,420 were identical and received through a Greenpeace campaign meaning 156 responses were from businesses or industry associations.
Timeframe for laying secondary legislation
- As to how most responded, 82% agreed that Defra should lay secondary legislation at the earliest opportunity with 30% saying the complexity of supply
chains would strongly impact how quickly businesses could prepare for the legislation, including a need to allow sufficient time to establish robust traceability and reporting systems and to communicate new requirements to suppliers.
- Impacts on business, indigenous people and local communities, and smallholders were also highlighted by a broad range of respondents, including NGOs and large businesses. Some specifically highlighted the need to consider the wider business environment, notably the impacts of EU Exit and COVID-19 on businesses and supply chains.
introduction of different forest-risk commodities
- In terms of how many commodities should be introduced in secondary legislation, 48% recommended option 1: to introduce 2 commodities in the first round of
secondary legislation. Many of these respondents emphasised the need to prioritise commodities with the largest environmental impact to support rapid action to address the challenges of biodiversity loss and climate change. Others viewed this option as providing balance, giving time for businesses to adequately prepare whilst achieving immediate impact in sectors that are more ready for regulation.
- 15% recommended option 2: to introduce 3 to 4 commodities in the first
round of secondary legislation. Common themes amongst those selecting this option included the view that a broader commodity scope could better tackle the scale and urgency of the environmental challenge, and the need to prioritise commodities with the largest environmental impact.
- 15% recommended option 3: to introduce 5 to 7 commodities in the first
round of secondary legislation. Almost half of these respondents
favoured introducing all commodities together to ensure fair and equitable burden across businesses. Other reasons provided included minimising any market distortion, unfair competition, and perverse incentives for businesses to change their commodity use. Greenpeace campaign responses (16,420 responses) advocated for the introduction of all 7 commodities within 12 months of the secondary legislation to support rapid action to tackle the UK’s illegal deforestation and land conversion footprint. The remaining 262 Global Witness campaign responses argued for regulation of a minimum of 5 commodities within 12 months of the secondary legislation.
- However, there was no detail as to which forest-risk commodities would be prioritised should Defra go with option 1 or 2.
- As for Defra's response, they mentioned that the government’s intention is to lay secondary legislation to implement due diligence regulations in the Environment Act at the earliest opportunity, but they have not mentioned when that will be.
- The design of the secondary legislation and accompanying guidance will be
informed by responses received through the consultation and published in due course, including how long businesses should have to prepare for regulation. BRC will keep members up to date when we hear more details.