Under the proposed UK law, businesses with turnover above £1 million that use materials linked to deforestation will need to be able to prove that these materials were harvested legally in the country of origin.

Which ingredients are set to be included?

The proposed legislation focuses on high-risk commodities most responsible for driving deforestation worldwide:

• Wood / paper
• Cattle
• Palm oil
• Cocoa
• Coffee
• Rubber
• Soy
• Chocolate

Crucially, the rules apply not only to these items in their pure form, but also to ingredients derived from them. This means, for example, that if a beauty product has an ingredient made from palm oil, the brand must be able to trace that ingredient to the specific plot of land where the oil palm tree was grown.

Which beauty products are affected?

The greatest compliance pressure will undeniably fall on products with palm oil and its thousands of complex chemical derivatives. Palm oil is one of the foundational elements in the beauty industry, acting as the base for emulsifiers, surfactants, emollients and texturisers found in everything from shampoos and lipsticks to anti-ageing creams.

But the rules will reach beyond palm oil derivatives and affect other products such as:

• Body lotions and lip balms containing cocoa butter
• Skin-conditioning agenda and Vitamin E derivatives that utilise soy
• Caffeine eye creams and exfoliating scrubs that contain coffee

Wood-derived packaging and cosmetic tools such as applicators and product seals containing rubber will also fall within the scope of the proposed changes.

Is your business ready?

While many larger, multinational beauty corporations have spent years mapping their supply chains, SMEs, which make up the majority of the UK beauty industry, face a steep learning curve.

Many beauty products contain ingredients sourced from dozens of different brokers, chemical processors and smallholder farms globally. Mapping each ingredient’s journey and verifying that it did not contribute to illegal deforestation can prove challenging for brands without sophisticated data tracking tools.

With a consultation launching later this year and legislation landing in 2027, the clock is ticking for businesses to get up to speed.

The British Beauty Council will engage with industry when the consultation is published to ensure the sector is fairly represented. 

In the meantime, click here for more information on the UK Government’s plans, or to see what’s been happening in Europe here.