UK deforestation crackdown puts beauty sourcing in spotlight amid EUDR delays

The UK government has announced a crackdown against illegal deforestation, with upcoming rules requiring companies that sell products sourced from rainforests to prove their supply chains are not linked to deforestation. The rules could impact sourcing in the beauty industry, as forest-risk ingredients such as palm oil derivatives, cocoa butter, and paper packaging are expected to be affected. 

Under the new rules, companies operating in the UK may need to prove where their key raw materials originate from, whether they were produced legally in the country of origin, and whether suppliers can provide reliable traceability data.

Beauty companies that use palm oil in their products, such as soaps, shampoos, cleansers, surfactants, emulsifiers, and emollients, may be particularly at risk.

The UK government says climate change, ecosystem deterioration, and ethical factors contributed to the push to phase out illegal deforestation from global supply chains.

According to the announcement, the UK’s consumption of consumer goods was linked to around 29,000 hectares of deforestation in 2023, and 9.4 million metric tonnes of related carbon emissions.

“We are leading by example and scrutinizing our own supply chains,” says Mary Creagh, the UK’s Nature minister. “Eliminating products linked to illegal deforestation not only helps to protect precious ecosystems but is good for our collective resilience and long-term prosperity.” 

Cocoa butter remains a key plant-derived ingredient in many moisturizing cosmetic products.The UK’s move comes as the EU Deforestation Regulation (EUDR) continues to face delays and industry pushback over implementation complexity.

The EUDR aims to prevent products linked to deforestation from being sold in the EU. It was supposed to come into force by the end of 2024, but has been postponed multiple times. Its latest timeline pushes the first phase of implementation to December 2026. By that time, Northern Ireland will have to comply due to its dual access to the UK Internal Market and the EU Single Market. 

EU alignment

The British Retail Consortium (BRC) welcomes the UK’s crackdown, but warns that it must align with the EU’s version to evade any operational complexity.

“We have long called for UK deforestation regulation as an important step in driving forest conservation across retail supply chains in line with business commitments, while supporting alignment with the EU where possible to avoid unnecessary costs and complexity for retailers and their customers,” says Andrew Opie, director of Food & Sustainability at the BRC.

“With the EU regulation due to take effect in Northern Ireland at the end of the year, it is important that the government takes a pragmatic approach to enforcement to minimize disruption for businesses and consumers.”

While alignment with the EUDR could make compliance smoother for companies operating across Great Britain, Northern Ireland, and the EU, it is unlikely to offer regulatory bliss. Businesses may still face some of the same traceability challenges and cost concerns that have delayed the EU regime.

The UK government will open a consultation later in the year where businesses, international partners, and civil society groups can comment on the details of the proposed deforestation policy. This consultation will also look at the Environment Act, which targets illegal deforestation, and the existing UK Timber Regulation.

Deforestation linked to palm cultivation can destroy habitats while feeding global demand for beauty and personal care ingredients.The government says that the consultation will propose that the upcoming framework covers the same core commodities and underlying information requirements that Northern Ireland will have to comply with at the end of the year. 

“With new rules finally coming into force in Northern Ireland at the end of the year, there is no excuse for further delay that would leave shoppers in the rest of the UK still unwittingly driving the destruction of the rainforest,” says Gavin Crowden, director of advocacy at the World Wildlife Fund (WWF).

Beauty’s environmental impact

The cosmetics industry uses many natural resources in product formulation. These ingredients are often assumed to be sustainable due to their natural origin and eco-friendly positioning, when in reality, naturally sourced ingredients often require large amounts of resources, such as land and water.

Personal Care Insights previously spoke with Thomas Collier, CEO at Levur, about palm oil as an example. He told us that an estimated forest area of 300 football fields is cleared every hour for palm plantations, highlighting the fine line between “natural” and “sustainable.”

Beauty consumers, regulation, and companies have long pushed for more ethical and sustainable production of cosmetics. However, complex supply chains can be difficult to track, which could make it hard for companies to back up sustainability messaging with concrete evidence. 

Larger beauty companies may already have programs and policies in place to ensure their raw material sourcing is ethical, through certification schemes or supplier audits, for example. But previous cases show that internal policies do not always shield companies from scrutiny.

Earlier this year, activist investor Oasis Management requested an independent investigation into Kao’s supply chain, after a commissioned report alleged the company sourced palm oil and pulp from suppliers linked to deforestation and human rights abuses.

Forest-risk commodities such as palm oil can enter cosmetics through long supply chains that are difficult to trace.Kao said it follows a No Deforestation, No Peat, No Exploitation policy and uses supplier monitoring systems, underscoring the difficulty of proving responsible sourcing across complex raw material networks.

The proposal for the independent investigation was officially voted down by Kao shareholders.

Alternatives rise

Ahead of the upcoming EUDR, and now the UK’s proposed version, chemical manufacturers have begun innovating alternatives to ingredients expected to be affected.

Sustainable fat-alternative ingredients company Savor, for example, entered the beauty sector from its original food and beverage positioning to launch palm-free, animal-free, and petroleum-free fats derived from captured carbon, for personal care applications. 

Researchers in Frankfurt have also engineered yeast enzymes to produce lab-made fatty acids that mimic those found in palm and coconut oil, providing a lower-impact alternative that dodges the deforestation and biodiversity loss associated with conventional sourcing.

For UK companies starting their compliance preparations, particularly those also operating in the EU, one direction could be to reformulate by using engineered alternatives of natural ingredients instead of agriculturally cultivated ones.