Practical guidance for hospitality & food service members
August 2026
Table of Contents
Understanding Forest Risk Commodities
Business Case for Taking Action
Your Five-Step Action Plan
The Carbon Opportunity with Mondra
Become Business Ready for Action
Useful Resources & Next Steps
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UNDERSTANDING FOREST RISK COMMODITIES
Forest Risk Commodities are agricultural products whose production is a driver of global deforestation. The term is defined in UK law under Schedule 17 of the Environment Act 2021, which describes a forest risk commodity as one that "has been produced from a plant, animal or other living organism" where "forest is being or may be converted to agricultural use for the purposes of producing the commodity."[I]
Deforestation
Loss of natural forest through conversion to agriculture, conversion to tree plantation, or severe and sustained degradation.
Conversion
Change of a natural ecosystem to another land use, or a profound change in species composition, structure, or function. Deforestation is a form of conversion.
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7 KEY FOREST RISK COMMODITIES
The 7 Key Forest Risk Commodities
Cattle / Beef
Soy*
Palm Oil
Cocoa
Coffee
Timber
Rubber
*Approximately 77-80% of global soy production is used in animal feed -chicken, pork, dairy and eggs rather than being consumed directly.
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DEFORESTATION VS CONVERSION FREE
Regulatory requirements for forest risk commodities
The European Union Deforestation Regulation (EUDR) currently covers deforestation only, However, industry best practice now uses the standard of DCF - Deforestation and Conversion Free - which is broader and protects non-forest ecosystems such as the Brazilian Cerrado savannah.
The UK's own regime, enabled under Schedule 17 of the Environment Act 2021 and currently under development, initially focuses on illegal deforestation, though the Government has stated an “aim to make sure these measures operate consistently alongside the EU Regulation on Deforestation-free Products (EUDR) ” and stated an intention to "move towards a deforestation-free standard" in due course [II].
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BUSINESS CASE FOR TAKING ACTION
The EU Deforestation Regulation (EUDR) comes into force for large and medium organisations in December 2026, and the UK Forest Risk Commodity Regulation (FRC) is expected to follow closely after EUDR.
Global GHG from land use
Land use change emissions, on par with the global transport sector [III].
Under-reported risk
Deforestation risk sitting on corporate balance sheets [IV].
Minimum EUDR fine
4% of annual EU turnover for non-compliance from December 2026 [V].
Consumer demand
73% of European consumers want deforestation-linked products off the shelf [VI].
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REGULATORY RISK
EU Deforestation Regulation (EUDR)
EUDR comes into force for large and medium organisations in December 2026, requiring proof that key commodities are not linked to deforestation. Non-compliance carries significant penalties: Article 25 of the regulation sets a minimum fine of 4% of total annual EU-wide turnover in the preceding financial year, in addition to potential confiscation of goods and revenues, and temporary exclusion from EU public procurement.
UK Forest Risk Commodities Regulation (FRC)
The UK FRC (Schedule 17 of the Environment Act) is expected to follow closely after EUDR. Under the proposals UK businesses who trade in commodities sourced from rainforests such as soy, palm oil, cocoa and rubber will need to check that their supply chains are not contributing to illegal deforestation. Early action puts you ahead of the curve.
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FINANCIAL & SUPPLY CHAIN RISK
Cocoa Price Volatility
Deforestation-linked supply chains are inherently volatile. Cocoa prices surged by 136% between July 2022 and February 2024, driven by climate stress in West Africa's cocoa belt, which produces around 70% of the world's cocoa. Global cocoa production fell by 14% in the 2023–24 season [VII].
$279 Billion Blind Spot
CDP's 2025 report found that companies are significantly under-reporting the financial risks tied to deforestation exposure, leaving an estimated US$279 billion blind spot in global markets. Across 827 disclosing companies, more than 1,200 substantive forest-related risks were identified, yet fewer than half had quantified financial impacts attached to them [IV].
Scope 3 Emissions Exposure
Land use change can represent 20–45% of your total Scope 3 emissions, making it one of the biggest levers in your net zero pathway [VIII].
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BRAND & REPUTATIONAL RISK
Consumer Scrutiny
Businesses not taking action to address deforestation risks face increasing media and stakeholder attention. Consumer awareness of supply chain sustainability is increasing.
73% Consumer Demand
WWF research indicates that around 73% of European consumers want deforestation-linked products removed from the market [VI].
SBTi FLAG Requirement
SBTi's FLAG (Forest, Land and Agriculture) targets require a deforestation policy as a condition of submission. Without one, you cannot set a credible science-based target.
Reputational risk is not theoretical. Media scrutiny of supply chain sustainability is intensifying, and brands that cannot demonstrate credible action are increasingly exposed to campaign pressure, investor questions, and customer attrition.
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YOUR FIVE-STEP ACTION PLAN
A structured framework for moving from awareness to verified, reportable action on forest risk commodities across your supply chain.
1. Map
Identify all forest-risk commodities - direct and embedded.
2. Identify & Prioritise
Rank by volume, origin and supplier concentration.
3. Commit
Publish a credible DCF policy.
4. Implement
Eliminate, switch, verify or certify.
5. Monitor & Report
Track KPIs and unlock carbon discounting.
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STEP 1 - MAP YOUR COMMODITY USE
- Work through your product specifications and ingredient lists. Commodities that are used directly (such as palm oil, cocoa and coffee) should be clearly identifiable with product specifications and/or technical files. Some forest risk commodities are allergens (soy, for example) so information is often already clearly recorded.
- Don't forget non-food items - palm oil fractions, in particular oleochemicals, appear in hand soaps and cleaning products used in your venues.
- Consider embedded forest risk commodities - commodities "hidden" inside finished or intermediate products, for example, soy and palm 'embedded' into animal feed. These commodities would not appear on an ingredient list, but had been utilised within the supply chain of the final meat or dairy product.
- Identify your key commodity suppliers - you may find that across hundreds of products, just 5–10 suppliers account for the bulk of your exposure.
Embedded soy example: A company who purchases chicken that was raised on soy-based feed has 'embedded' soy in their supply chain, despite not directly purchasing the soy itself. The Consumer Goods Forum (CGF) offers a framework known as the 'Soy Ladder' [IX].
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STEP 2 - IDENTIFY RISK & PRIORITISE
Prioritisation Approach
- Prioritise by volume and origin. Latin American soy, South American beef, West African cocoa, and Southeast Asian palm carry the highest deforestation risk.
- Tools to identify risks include Trase, a platform that maps global trade data. Its impact indicators map ranks countries, regions, and trading companies by deforestation risk per tonne of certain commodities exported. Global Forest Watch is a forest monitoring platform that provides near-real-time forest cover loss alerts down to farm level.
- Use country-of-origin data, NGO reports, and industry tools to assess risk levels by sourcing region. Trase and Global Forest Watch can provide country-of-origin forest risk data, alongside national deforestation statistics, whilst NGO reports (e.g. WWF, Mighty Earth and Global Witness) can provide, qualitative, investigation-driven evidence on risks.
- Industry tools include the EFI Commodity Convertor tool, which helps to convert derived product volumes back into raw commodity equivalents, and AFI’s operational guidance which supports companies in implementing AFI’s Core Principles and definitions within supply chains. The EUDR deforestation risk benchmarking (e.g. low, standard or high) can also be used to assess the risk level of a sourcing region.
Ask Your Suppliers
How many forest risk commodities do you use, and how much?
What certification or verification scheme covers the commodities you supply to us?
Where do these commodities come from?
Do you have a DCF policy?
What is the cut-off date for your scheme?
Is your scheme independently audited?
What chain of custody model does your certification use?
Can you provide documentation showing physical traceability?
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STEP 3 - MAKE A COMMITMENT
The Accountability Framework initiative (AFi) is the globally recognised, consensus-based standard for what a credible DCF policy should contain. Its How to Write a Strong Ethical Supply Chain Policy user guide and Core Principles set out the required elements in detail. The five components below draw directly from that guidance.
Context and Scope
Why your business is taking action; demonstrate you understand the risks.
Which suppliers, commodities, operations and geographies are covered; apply consistently to UK, EU and international supply.
Clear Commitment, Target & Milestones
Including cut-off dates - the date after which no commodity produced on deforested land can enter your supply chain. Note: the key cutoff date to consider is 2020 to align with EUDR.
Implementation Mechanisms
Which forms of evidence are accepted as demonstrating compliance with the policy, for example which certification schemes are accepted, or what alternative verification approaches are recognised.
Peer Collaboration
Explain how you intend to share learnings and work collaboratively with peers. Review what others are doing, for example via the UK Soy Manifesto public commitments page and the Accountability Framework Initiative (AFI).
Consider methodology for non-compliance process:
The Accountability Framework provides guidance on managing supplier non-compliance, recognising the importance of working with suppliers to resolve existing non-compliances and prevent future occurrences. Core Principle 6 of the Accountability Framework emphasises the need for a clear, consistent, and documented policy and procedure for addressing supplier non-compliance. Examples of approaches and methods for managing non-compliance can be found here. Tip: Publish your policy on your company website and report on progress annually to build credibility.
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STEP 4 - DEVELOP YOUR IMPLEMENTATION PLAN
This is where you decide how to address deforestation risk in your supply chain. Depending on the approach you take, and the chain of custody associated with that approach, implicates the ability to make carbon discounting claims (refer to section: The Carbon Opportunity with Mondra). Work through this decision framework for each commodity:
Option A - Eliminate the Commodity
Remove the commodity from your supply chain entirely. Removes risk completely. Consider whether the replacement is better for people and planet (e.g. palm is a highly efficient commodity, producing 2–2.5x more vegetable oil per hectare than alternatives).
Option B - Source from Lower-Risk Origins
Switch to suppliers sourcing from lower-risk countries (e.g. Canadian or European soy instead of Latin American). Reduces risk, but you lose commercial influence over improving sustainability in high-risk regions. Still requires evidence.
Option C - Verification
Utilise assurance systems that trace commodities back to farm level, checking they are legal and deforestation-free. No consumer-facing logo but provides legal compliance evidence.
Option D - Certification
Established standards with consumer-facing logos. Key examples: RTRS / Proterra (Soy), RSPO (Palm Oil), FSC (Timber).
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STEP 5 - MONITOR, REPORT AND COMMUNICATE
Integrate key KPIs to track progress:
Volume & Origin
Volume and origin of each forest risk commodity in your supply chain.
% Verified as DCF
Certified or verified, and which scheme/standard applies.
% Suppliers with DCF Commitment
Shows your influence beyond your own products.
Support for Sustainable Production
Where you cannot claim that commodities in your supply chain are fully deforestation and conversion free (due to lack of physical traceability), it may still be possible to claim that you are supporting sustainable production in landscapes that are at risk, e.g. by purchasing certified credits,
Actions Underway
What have you done this year, and plan to do in the year ahead, to further progress against your deforestation and conversion free policy? Actions might include becoming a member of an industry working groups or engaging in supplier training. What are your next steps, and direction of travel?
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THE CARBON OPPORTUNITY WITH MONDRA
Getting DCF traceability unlocks significant carbon reporting benefits under the Land Sector Removal Standard (LSRS) and supports EUDR compliance. This chapter explains how physical traceability translates directly into measurable, reportable carbon reductions.
Land use change = ~20% of Scope 3
Land use change accounts for ~20% of total Scope 3 food supply chain emissions on average.
Land use change can be 45%+ of Scope 3 for meat-heavy businesses - the single biggest lever available.
Opportunity to report emissions reduction
If you know the cut-off year for deforestation events in your supply chain, you can apply linear discounting, meaning your reported land use change emissions reduce year on year.
53% Reduction Example
1,000 tonnes of chicken with a 2008 cut-off date drops from ~3,890 to ~1,830 tonnes CO₂e [VIII].- Cut off year makes a difference!
DCF Sourcing Scheme
Switching to a DCF sourcing scheme counts as a year-on-year reduction you can report immediately.
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UNDERSTANDING CHAIN OF CUSTODY MODELS
This determines what claims you can make and how carbon can be discounted:
Segregated
Certified material is physically kept separate at every stage. Fully compliant - strongest claim with direct physical link to farm. Higher cost; gold standard for carbon reporting.
Controlled Mass Balance
Certified and non-certified material are mixed at a controlled, early point (e.g., mill, crushing plant). Compliant in some circumstances if physical traceability back to the original processing facility exists. Moderate claim strength.
Standard Mass Balance
Certified and non-certified material can mix at any point; only volumes are tracked via an administrative/accounting system. Limited acceptance - hard to make credible claims without physical traceability.
Credits / Book and Claim
Sustainability attributes are fully decoupled from the physical product. Do not count for carbon discounting. Still a good starting point since the premium supports sustainable farmers, but it does not help with carbon accounting.
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ENGAGING YOUR BUYING TEAMS
What to Check Against Each Credential
Give your buying and procurement teams clear guidance on what to accept. Once Step 2 supplier answers come back, buying and procurement teams should check each credential against:
Does the scheme actually have DCF criteria?
Does it cover the product volumes being supplied to you?
What chain of custody model applies?
Is it independently audited?
What is the cut-off date?
Get Expert Validation
Organisations like Efeca can review your current scheme and confirm whether it meets traceability requirements to apply LUC discounting in your footprint. For many suppliers this is a gap analysis against existing documentation - not a major project.
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BECOME BUSINESS READY FOR ACTION
Internal alignment, leadership buy-in, and collective engagement are the foundations that make your DCF commitments credible, durable, and impactful beyond your own supply chain.
Internal Buy-In
Use multiple angles with leadership — sustainability, cost risk, supply resilience, legislative requirements, customer expectations.
Beyond Your Supply Chain
Engage branded suppliers, invest in sourcing regions, and join collective groups to amplify impact.
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GET INTERNAL BUY-IN
Use Multiple Angles with Leadership
Sustainability, cost risk, supply resilience, legislative requirements, customer expectations. Don't rely on one argument.
Model the Impact
Quantify what DCF sourcing means for your carbon footprint and net zero targets. Make it tangible.
Embed It in Strategy
Make DCF a named pillar in your net zero pathway, not a side project.
Assign a Leadership Sponsor for Each Commodity/Project
Drives accountability and opens doors.
Be Transparent About Costs
Leadership decisions are better made with full information. This includes the on-cost of transitioning but also the financial, reputational and operational costs of not taking action. The short term costs of mitigating climate impacts are often much smaller than addressing impacts later down the line.
Upskill Broadly
Buying teams, technical teams, and senior leaders all need to understand the basics.
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BEYOND YOUR OWN SUPPLY CHAIN
Once your product compliance is in order, consider:
Engaging Branded Suppliers
Share your progress and ask them to take action (this still affects your Scope 3 footprint).
Investing in Sourcing Regions
Farmer training programmes, landscape-level initiatives.
Joining Collective Groups
Zero Carbon Forum, UK Sustainable Commodities Initiative (UKSCI), UK Soy Manifesto. Collective action reduces your individual workload and creates supplier-wide momentum.
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USEFUL RESOURCES & NEXT STEPS
A curated set of tools, platforms, and collective initiatives to help you move from commitment to verified action - without duplicating effort already done by peers.
Start Here
Pull your product specifications, contact your top 5–10 commodity suppliers, and draft or update your deforestation policy.
Join Collective Groups
UKSCI, UK Soy Manifesto, Zero Carbon Forum - access shared resources and reduce duplication.
Unlock Carbon Discounting
Talk to your carbon reporting team about land use change discounting under LSRS. Expert support available from Efeca and Mondra.
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WHERE TO START - SUMMARY
Pull Your Product Specifications
Identify which of the 7 commodities appear - directly and embedded.
Estimate Your Soy Footprint
Use a conversion factor tool to estimate your soy footprint if you don't have supplier data.
Contact Your Top Suppliers
Contact your top 5–10 commodity suppliers and ask what DCF assurance they already have.
Draft or Update Your Deforestation Policy
Even a simple public statement is a meaningful starting point.
Join a Collective Group
UKSCI, UK Soy Manifesto - access shared resources and reduce duplication.
Talk to Your Carbon Reporting Team
Unlock land use change discounting under LSRS - it may be the single biggest reduction available to you this year.
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KEY RESOURCES
UK Soy Manifesto
See peer commitments; understand what good looks like. UK Soy Manifesto
Efeca Sustainable Commodities Resource Hub
Platform of information, tools and resources to help understand sourcing sustainable and legal forest-risk commodities. Efeca Sustainable Commodities Resource Hub
Accountability Framework Initiative (AFI)
Best practice guidance; policy templates for different supply chain positions. Accountability Framework Initiative (AFI)
RTRS Conversion Factor Tool
Estimate soy volumes from product weights. RTRS conversion factor tool
WWF's Riskier Business
Report focused on the impacts resulting from the UK's trade in the seven agricultural and forest commodities. WWF’s Riskier Business
AIC Sustainable Commodities Scheme
Launching Q3 2026 — DCF assurance for UK animal feed. AIC Sustainable Commodities Scheme
Mondra
Expert support on carbon modelling and DCF implementation. Mondra
Zero Carbon Company Free Carbon Calculator
Free Basic Carbon Calculator. Zero Carbon Company Free Carbon Calculator
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SOURCES
Environment Act 2021, Schedule 17, paragraph 1. UK Parliament. https://www.legislation.gov.uk/ukpga/2021/30/schedule/17/enacted
UK Government, "The UK's Approach to Deforestation Regulations", GOV.UK. https://www.gov.uk/government/publications/the-uks-approach-to-deforestation-regulations/the-uks-approach-to-deforestation-regulations
WWF-UK, "The Soy Story". https://www.wwf.org.uk/updates/soy-story; Our World in Data, "Soy" (citing University of Oxford Food Climate Research Network / USDA PSD data). https://ourworldindata.org/soy
UNFCCC, "Land Use, Land-Use Change and Forestry (LULUCF)." https://unfccc.int/topics/land-use/workstreams/land-use--land-use-change-and-forestry-lulucf
EUDR Article 25 penalties. Forest Policy Group / FGP. https://forestpolicy.org/policy-law/eu-regulation-deforestation-free-products-eudr; FoodNavigator, "EUDR: Penalties of non-compliance", July 2025. https://www.foodnavigator.com/Article/2025/07/22/eudr-penalties-of-non-compliance/
Climate Central, "Climate change is heating up West Africa's cocoa belt", 2025. https://www.climatecentral.org/climate-matters/climate-and-cocoa-2025
CDP, Blind Spots on the Balance Sheet: Uncovering Financial Implications of Deforestation, November 2025. https://www.cdp.net/en/insights/uncovering-financial-implications-of-deforestation
Mondra, Deforestation Webinar 2, in partnership with Efeca and Zero Carbon Forum, 2026.
WWF consumer research figure, as cited in: FoodNavigator, "EUDR: Penalties of non-compliance", July 2025.
KPMG & Consumer Goods Forum, “A framework for the measurement of soy usage in consumer goods businesses”, 2015 https://thecollaborativesoyinitiative.info/storage/files/proforest-2024-guidance-embedded-soy.pdf
Efeca, “UKSCI Annual Progress Report,” January 2026, https://www.efeca.com/wp-content/uploads/2024/03/UKSCI-APR-January-2026.pdf
Accountability Framework initiative (AFi). How to Write a Strong Ethical Supply Chain Policy (user guide). https://accountability-framework.org/how-to-use-it/resources-library/how-to-write-a-strong-ethical-supply-chain-policy/;
Elbersen et al.,Wageningen University, “Comparative study on the sustainability of vegetable oils”, 2025, https://edepot.wur.nl/695647
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TAKING ACTION ON FOREST RISK COMMODITIES