Deforestation regulation is moving rapidly from policy into operational reality. The EUDR will begin applying in Northern Ireland and across the EU at the end of 2026, while the UK Government has set out its intended approach for a broadly aligned Great Britain regime. This is an important step forward. But it is not the full answer.
The new requirements will demand more evidence than many businesses have historically been used to providing, including geo-location data linked to sourcing. However, the reliability of that evidence depends upon the accuracy and integrity of the underlying supply-chain information. In many cases this remains a paper trail rather than actual verification. This tension sits at the heart of the regulation.
“The regulation is a necessary step in the right direction,” says Simon Cole, CEO of Bia Analytical. “But it is still largely a process-driven framework. It defines what businesses are expected to do, rather than what they are expected to prove.”
A framework built on process
The UK’s approach focuses on due diligence. Companies are expected to assess risk, review suppliers and maintain appropriate documentation.
These are essential controls and most businesses will already have some of these systems in place.
The issue is that process does not always equal certainty.
“Compliance frameworks are designed to show that reasonable steps have been taken,” says Simon Cole. “They don’t always confirm that the outcome is accurate. That is where the risk begins.”
As supply chains come under greater scrutiny, this distinction becomes more important.
Where traceability falls short
Traceability has long been the backbone of supply chain compliance. Businesses rely on supplier declarations, certifications and origin records to demonstrate where products come from.
These tools are useful, but they have limits.
In complex, multi-tier supply chains, information is often passed through several layers. It can be outdated, incomplete or, in some cases, inaccurate.
“Traceability tells you where something should come from,” says Simon Cole. “Verification is what tells you whether that is actually the case.”
For high-risk commodities such as soy, this gap is well understood.
Several investigations have highlighted cases where soy from areas linked to illegal deforestation was able to enter international supply chains through indirect sourcing routes or weaknesses in traceability systems. These examples are not evidence of widespread malpractice by compliant businesses. Rather, they demonstrate how difficult it can be to verify complex supply chains using documentation alone. Global soy supply chains are vast and interconnected. Sourcing spans multiple continents and involves a wide mix of growers, traders and processors. At the same time, industry groups are increasingly working towards “verified deforestation- and conversion-free” soy, which reflects a wider shift in expectations towards evidence rather than assurance alone.
This is no longer an abstract challenge. At Bia Analytical, this has already been tested in practice.
“In our soybean work, we analysed more than 1,000 samples and built a global reference dataset covering 21 countries,” says Simon Cole. “We were able to demonstrate that origin determination is achievable at scale.”
The work demonstrates that scientific approaches can support supply chain transparency in practice, not just in theory.
Scrutiny is increasing across the board
Regulation does not exist in isolation. At the same time as deforestation rules are being introduced, scrutiny of environmental claims is increasing.
Regulators are taking a closer look at sustainability messaging. NGOs are more active in challenging sourcing claims. Customers and consumers are asking more questions.
The EU is also continuing to develop its own deforestation framework. While the details are still evolving, it is likely to influence expectations across the UK market, particularly for businesses trading across borders.
“The pace of change is coming from multiple directions,” says Simon Cole. “Regulation is only one part of it. Market expectations are moving just as quickly, if not faster.”
Why verification is becoming standard practice
In this environment, many businesses are starting to rethink how they approach supply chain assurance.
Documentation remains important, but it is no longer seen as sufficient on its own.
Independent verification is becoming a more common part of the picture.
Analytical testing can provide objective insight into key attributes such as raw material identity, composition and geographic origin. It offers a way to check that what is declared is consistent with what is actually being supplied.
“When your claims are challenged, documents explain your process,” says Simon Cole. “Data is what supports your position.”
This is particularly relevant in categories where supply chains are complex and exposure to risk is higher.
“Most businesses trust their suppliers, and in most cases that trust is well placed. But history shows that organisations affected by fraud or misrepresentation once trusted their suppliers too,” says Simon Cole. “Verification isn’t about replacing trust. It’s about providing evidence that trust is justified.”
A changing landscape for sustainability claims
The implications go beyond compliance.
Statements such as “deforestation-free” or “responsibly sourced” are increasingly being treated as claims that need to be supported.
If there is a gap between what is said and what can be evidenced, the consequences can extend to brand reputation as well as regulatory risk.
“Sustainability claims now carry real accountability,” says Simon Cole. “If they cannot be backed up, they create exposure rather than value.”
This is one of the key drivers behind the shift towards verification.
What comes next
The current UK framework is focused on illegal deforestation. However, the wider direction of travel suggests expectations will continue to evolve.
Developments in the EU, along with pressure from stakeholders, are likely to raise the bar over time. Businesses may find themselves needing to demonstrate not just that they have processes in place, but that those processes are delivering reliable outcomes.
“There is a clear movement from demonstrating process to demonstrating proof,” says Simon Cole.
Moving from paperwork to proof
For businesses, this creates a strategic choice.
Some will treat deforestation regulation purely as a compliance requirement. Others will see it as an early signal of a broader shift in how supply chains are assessed.
“The organisations that get ahead will be the ones that strengthen their approach now,” says Simon Cole. “That means going beyond documentation and building systems that can stand up to scrutiny.
“We are already seeing this shift in parts of the meat industry, where inline verification is becoming part of the emerging norm. It allows every cut to be checked for species, breed and origin. It stands to reason that this approach will extend into other high-risk supply chains over time.”
And for many businesses, that shift is happening faster than expected, because the question is changing.
It is no longer:
Have you completed your due diligence?
It is:
Can you prove it?
