The European Union Deforestation Regulation has already generated plenty of discussion in agriculture, food, forestry and consumer goods. But I have barely seen it discussed at all in the context of the attractions industry; I would most definitely consider that a blind spot.
Because while the law may sound like a “tree problem”, its scope reaches well beyond timber. It applies to seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, and to a long list of derived products made with them.
The European Commission describes it as a set of “EU rules to guarantee that the products EU citizens consume do not contribute to deforestation or forest degradation worldwide.”
That matters for museums, theme parks, water parks, zoos, aquariums, immersive operators, retailtainment businesses, brands and suppliers.
This is because exposure may sit in places that do not immediately look like “forest” issues: coffee in food and beverage, chocolate in retail, leather in merchandise or seating, paper in packaging and print, wood in fit-out and furniture, rubber in countless components and products, and palm-derived inputs further upstream in goods that arrive fully finished.
The issue is not whether an attractions operator is buying logs or raw cocoa beans directly. The issue is whether the products, materials and branded goods moving through the business contain, use or depend on regulated commodities.
At its core, this regulation is about market access. In-scope products cannot be placed on the EU market, made available on it, or exported unless they are deforestation-free, legally produced in line with the law of the country of production, and backed by the required due diligence information.
That is why the regulation deserves more attention in this sector than it has received so far.
Much broader than a “tree problem”
One reason the law is easy to underestimate is that many people hear “deforestation” and immediately think of wood, trees and a trip, maybe a trip to the German Black Forest. Wood is certainly part of it, but so are cattle, cocoa, coffee, oil palm, rubber and soya, along with many products derived from them.
EY’s summary of the regulation usefully spells this out, noting that covered goods include “cattle, cocoa, coffee, palm oil, rubber, soy, wood, as well as certain related products such as leather, chocolate, certain furniture, tyres, paper or natural rubber spare parts.”
That breadth matters for the attractions ecosystem.
A zoo café selling coffee and chocolate products, a museum shop carrying leather accessories or paper-heavy branded goods, a theme park fitting out retail or food spaces with timber products, an immersive venue buying rubber-based materials through contractors, or a supplier manufacturing guest-facing products with wood, paper or rubber inputs may all find themselves much closer to the regulation than expected.
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The law is not just about who sits nearest the farm or forest. It is about what sits inside every single product that ultimately reaches the market.
Operators, suppliers and brands all need to pay attention
The legal categories matter here. Depending on the product and the transaction, a company may be acting as an operator, a downstream operator or a trader.
In plain English, the obligation shifts depending on whether the company is first placing an in-scope product on the EU market, making a product already in the chain available, or placing on the market a product made using other relevant products.
For the attractions industry, that means role confusion is likely to be one of the first practical challenges. A venue operator may assume the issue belongs to its supplier. A supplier may assume the issue belongs to the importer. A brand licensing team may assume the issue sits elsewhere entirely.
In reality, different actors across the ecosystem may have different obligations depending on the chain structure and the product involved. The law does not care much for internal assumptions or comforting organisational myths.
Why this is about far more than trees
The real significance of the regulation is not only environmental. It is operational. PwC puts it quite clearly: “Compliance will have to be based on much more than a simple box-ticking exercise.”
That is exactly right. The regulation requires companies to move beyond broad sourcing claims and toward evidence: product information, supplier information, country of production, traceability, geolocation data, risk assessment, record-keeping and, where needed, risk mitigation.
That is why I think this law is better understood as a supply-chain visibility test as much as a forest rule.
In an article published in late 2025, EY makes a similar point from a different angle, saying compliance with the regulation requires “transformative changes in sourcing practices” and that successful adaptation can help create “lasting structural resilience in global supply chains.”
Those are not small words, but they feel justified. For many businesses, the hard part will not be reading the law. It will be turning fragmented procurement, supplier and product information into something usable, structured and defensible.
And that challenge is especially relevant in sectors where sourcing is often indirect. Attractions businesses frequently buy through contractors, manufacturers, distributors, concessionaires, franchise structures or branded product partners.
That distance can create the illusion that the problem belongs upstream. It does not. The regulation is designed precisely so that obligations and accountability travel through value chains.
See also: Sustainable supply chains: how to drive real change
The biggest vulnerability lies in indirect sourcing, which is part of most supply chains
Many organisations in the visitor economy do not consider themselves exposed because they are not commodity traders. Fair enough. They are trying to run parks, exhibitions, attractions, guest experiences and retail offers, not moonlight as cocoa brokers or even coffee roasters.
But that is precisely why this can become a blind spot.
A company may have a responsible sourcing policy, a supplier code and the occasional spreadsheet heroically stitched together five minutes before a meeting. What it may not have is genuine visibility into which suppliers, products and categories deserve deeper scrutiny first.
That matters because enforcement is risk-based, but company responsibility is not optional. Authorities in Member States are required to carry out minimum levels of checks depending on the country risk tier.
For high-risk countries, the law requires annual checks covering at least 9% of relevant operators, non-SME downstream operators, and non-SME traders, and at least 9% of the quantity of each relevant product.
For standard-risk countries, the minimum is 3%, and for low-risk countries, 1%.
These percentages are often misunderstood. They are not telling companies that only a small part of the problem matters. They are telling us that enforcement itself is being organised around risk.
That is a useful clue for business strategy. Companies still need a rational way to prioritise where to go deeper: categories with regulated commodities, suppliers with weak documentation, customer-facing products, materials that are hard to substitute, complex chains, and sourcing routes where visibility quickly disappears after tier one.
The smartest response is not to panic, and it is not to pretend every product carries identical urgency. It is to build a broad snapshot and then go deeper where risk and business importance intersect.
The downside is real
Unlike some of the regulations in the supply-chain scene across the European continent, this one is not symbolic. The European Deforestation Regulation requires Member States to impose penalties that are effective, proportionate and dissuasive.
Those penalties can include fines, confiscation of products, confiscation of revenues, temporary exclusion from public procurement and public funding, and temporary prohibition from placing products on the market or exporting them.
For legal persons, the maximum amount of the fine must be at least 4% of the annual Union-wide turnover.
There is also a digital enforcement architecture behind it.
The Commission states that “The Information System is operational.” That may sound administrative, but it matters. It shows that this is not just a policy aspiration floating around Brussels. It is being translated into systems, statements and enforcement workflows.
At the same time, implementation has not been static. Reuters reported the Commission’s effort to reduce paperwork, including annual rather than shipment-by-shipment due diligence reporting in some cases, while preserving the substance of the law.
As Commissioner Jessika Roswall put it, “Our aim is to reduce administrative burden for companies while preserving the goals of the regulation.”
That is an important nuance. The implementation path may become somewhat more practical, but the direction of travel remains the same.
For many businesses, the biggest risk may not even be the headline fine.
It may be the friction: last-minute evidence requests, supplier delays, internal confusion over ownership, documentation gaps in commercially important categories, and the dawning realisation that some products central to the guest offer are supported by much weaker information than anyone had hoped.
The opportunity is more interesting than it first appears
It would be easy to end here and call this just another compliance burden. That would be true, but incomplete. And a little depressing.
The more interesting possibility is that regulations like this push companies to become better at understanding what they buy, from whom, and with what level of evidence.
That can mean cleaner supplier data, stronger onboarding, more disciplined product information, more structured documentation flows and better supplier conversations. It can also change how supplier quality is assessed.
Price, design and delivery timelines will still matter, obviously. But so will documentation quality, responsiveness and traceability.
That is why I do not think the attractions sector should read the European Union Deforestation Regulation only as a story about trees. It is also a story about visibility. About whether operators, suppliers and brands actually understand the products and materials behind the experiences they create.
And perhaps that is the bigger lesson here.
The regulation may have been written to tackle deforestation, biodiversity loss and emissions. But for this industry, it also poses a quieter and more revealing question: who really understands their supply chain, and who has simply been hoping for the best with better branding?
This may be a slightly uncomfortable question, but it is also increasingly a strategic one.
