Deforestation-Free Supply Chain

A deforestation-free supply chain is one in which specified commodities and products derived from them can be verified as not having contributed to deforestation or forest degradation anywhere in the world after a defined reference date. In the European regulatory context, EU Regulation 2023/1115 on deforestation-free products (the EU Deforestation Regulation, or EUDR) is the primary legal instrument driving this requirement, making it progressively relevant to public procurement as buyers demand supply chain evidence from their contractors.

What is a Deforestation-Free Supply Chain?

EU Regulation 2023/1115, adopted in 2023, prohibits the placing on the EU market of seven commodities and products derived from them unless they are deforestation-free and produced in accordance with the relevant legislation of the country of production. The seven in-scope commodities are cattle, cocoa, coffee, palm oil, soya, wood, and rubber, along with derived products such as leather, chocolate, furniture, paper, and tyres.

Operators placing these products on the EU market must carry out due diligence and submit a due diligence statement to an EU information system before the product enters or leaves the market. The regulation uses 31 December 2020 as the reference date: land from which these commodities originate must not have been deforested or degraded after that date.

For public procurement, the EUDR creates a direct and growing obligation. A contracting authority procuring timber furniture, paper and printing services, food catering, or construction materials that include tropical hardwoods may include deforestation-free requirements in its technical specifications, drawing on the legal framework that the EUDR provides. The GPP Criteria (EU) for categories such as food and catering services and timber products already require evidence of sustainable and legal forest origin, typically through certification schemes such as the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC). The EUDR strengthens and extends this logic by creating a verifiable traceability obligation backed by regulatory enforcement.

Contracting authorities applying Green Public Procurement (GPP) standards can reference EUDR compliance as a technical specification minimum: all supplied wood-based products must be accompanied by a valid due diligence statement under Regulation 2023/1115. This is particularly relevant for contracts covering office furniture, construction and refurbishment works, printing and paper supplies, and food service.

The Corporate Sustainability Reporting Directive (CSRD) also intersects here, as large companies must disclose their policies and outcomes on deforestation in their sustainability reports. Suppliers subject to CSRD reporting will hold documented deforestation due diligence data that contracting authorities can request during selection or award evaluation.

In the UK, the Environment Act 2021 introduced a forest risk commodities regime (Schedule 17) that prohibits commercial use of forest risk commodities produced on illegally deforested land. While the UK regime differs from the EUDR in scope and enforcement mechanism, UK contracting authorities and suppliers who trade with the EU face dual compliance obligations. Sustainable Public Procurement (SPP) and Socially Responsible Public Procurement (SRPP) frameworks in the UK also encourage buyers to require evidence of legal and sustainable sourcing from commodity supply chains.

Why deforestation-free supply chains matter for bidders

Suppliers of in-scope commodities and derived products bidding on European public contracts face increasing specification requirements for supply chain traceability and deforestation-free certification. Buyers in categories such as food catering, furniture, construction, and paper procurement are already asking for FSC or PEFC certification and will increasingly require EUDR-compliant due diligence statements. Suppliers who cannot demonstrate a verifiable deforestation-free supply chain risk exclusion from contracts in these categories.

Beyond compliance, demonstrating a robust deforestation-free supply chain is increasingly linked to scoring on fair trade and environmental award criteria. Authorities that apply life-cycle assessment (LCA) approaches to evaluate the environmental impact of goods will find that deforestation-related land-use change is a material component of the life-cycle carbon footprint, particularly for food and timber products.

Example

A Swedish county council tenders for canteen catering services across its public schools. The technical specification requires that all beef, coffee, and palm oil ingredients be traceable to verified deforestation-free sources under Regulation 2023/1115 or equivalent national legislation, supported by EUDR due diligence statements or Rainforest Alliance certification. An award criterion allocates 15 points to the proportion of ingredients sourced from deforestation-free certified producers. A caterer who cannot demonstrate supply chain traceability fails the minimum threshold; one who provides full traceability for all seven EUDR commodities scores maximum points on this criterion.

Frequently Asked Questions

Which commodities are covered by the EU Deforestation Regulation?

EU Regulation 2023/1115 covers cattle, cocoa, coffee, palm oil, soya, wood, and rubber, and derived products such as leather, chocolate, furniture, paper, tyres, and printed books. The regulation applies to products placed on the EU market regardless of where they were produced.

How do I demonstrate deforestation-free sourcing to a contracting authority?

The primary mechanism under the EUDR is a due diligence statement submitted to the EU information system before the product enters the market. In addition, widely recognised third-party certification schemes such as FSC, PEFC, Rainforest Alliance, and RSPO (for palm oil) provide audited chain-of-custody evidence that contracting authorities commonly accept. Buyers may also request geographic coordinates of the land on which the commodity was produced, as the EUDR requires operators to collect and verify this geolocation data.

Does this apply to construction contracts as well as goods and catering?

Yes, where the contract involves timber-based products such as structural timber, wood-based panels, or wooden flooring and furniture, deforestation-free requirements can be embedded in the technical specification. Construction contracts that involve tropical hardwoods or composite wood products are particularly likely to attract these requirements. Bidders on construction and refurbishment works should audit their material supply chains for EUDR-covered products before tendering for European public contracts.