Forests

CDP Forests: how to disclose deforestation risk in 2026

Cristina Alcalá-Zamora · · 9 min read
CDP Forests: how to disclose deforestation risk in 2026

Photo by Maxim Berg on Unsplash

Why Forests is the most demanding CDP module

CDP Forests is, by some margin, the most data intensive of the three CDP questionnaires. Climate Change asks for emissions across well defined GHG Protocol categories. Water Security asks for flows by site. Forests asks for something fundamentally harder: where a physical commodity came from, in what volume, with what certification, and whether it was produced on land deforested after a cutoff date.

That is a traceability problem, not a measurement problem. And it is the same traceability that the EU Deforestation Regulation (EUDR) now makes a legal requirement for placing covered commodities on the EU market. Companies preparing for EUDR often find their CDP Forests response improves automatically, and vice versa.

The seven covered commodities

CDP Forests covers commodities historically associated with deforestation:

  • Timber and timber products including paper and pulp.
  • Palm oil and derivatives.
  • Soy including soymeal and soy oil.
  • Cattle products including beef and leather.
  • Natural rubber.
  • Cocoa.
  • Coffee.

If your business handles any of these directly, or indirectly through ingredients, packaging materials, or animal feed, you are within scope. The indirect path catches more companies than they realise. A confectionery brand handles cocoa, palm oil, and packaging timber. A pet food brand handles soy and beef. A furniture retailer handles timber, leather, and rubber. A dairy company handles soy in animal feed.

What the questionnaire asks

CDP Forests organises questions around three pillars per commodity, repeated for each one in scope.

1. Volumes and traceability

For each covered commodity, you report:

  • Volumes consumed or produced, in metric tonnes.
  • Sourcing geography, ideally to municipality or jurisdiction level.
  • Traceability level: country, region, sub region, mill or production unit.
  • Risk assessment in your supply chain.

Reaching the higher scoring bands requires traceability to the production unit (palm oil mill, soy crusher, cattle ranch, cocoa cooperative) for at least the highest risk volumes.

2. Certification and verification

Coverage of credible certification schemes with proper chain of custody:

  • RSPO for palm oil (segregated and identity preserved scoring better than mass balance).
  • FSC and PEFC for timber.
  • RTRS, ProTerra, ISCC for soy.
  • Rainforest Alliance, UTZ, Fairtrade for cocoa and coffee.

CDP rewards mass balance volumes lower than physically segregated supply. A claim of “100 percent RSPO” counts very differently when it is mass balance versus segregated.

3. Policies, targets, and engagement

A no deforestation, no peat, no exploitation (NDPE) policy with:

  • A clear cutoff date (commonly 2020 or earlier).
  • A monitoring and verification mechanism.
  • Time bound targets per commodity.
  • Supplier engagement programmes with measurable outcomes.

What scores well

Across A list responses, common patterns emerge:

  • Production unit traceability for primary risk commodities, even if at a smaller percentage. 60 percent of palm oil traceable to mill scores better than 100 percent traceable to country.
  • NDPE policy with 2020 or earlier cutoff and an explicit verification mechanism.
  • Quantitative deforestation free volume, not just certification claims. Increasingly, companies report deforestation free volumes verified by satellite monitoring tools.
  • Active supplier engagement with non compliance protocols. Scorers want to see what happens when a supplier fails to meet the policy.
  • Public reporting alignment with Accountability Framework Initiative (AFi).

Common pitfalls

Repeated errors that drag down forest scores:

  • Confusing certification with deforestation free claims. RSPO mass balance does not guarantee deforestation free supply. Scorers know the difference.
  • Country level traceability passed off as full traceability. CDP penalises this in the scoring methodology.
  • Policies without cutoff dates or with cutoffs after 2020.
  • Soft engagement with non compliant suppliers. A supplier engagement programme without consequences for non compliance does not score.
  • Skipping commodities because volumes are small. CDP looks at materiality. Even small volumes of palm oil in a confectionery range matter.

How CDP Forests aligns with EUDR

The EU Deforestation Regulation is the most consequential change in this space. From its application date, companies placing covered commodities (cattle, cocoa, coffee, palm oil, rubber, soy, wood, plus several derived products) on the EU market must demonstrate:

  • The commodity is deforestation free since 31 December 2020.
  • Production complies with relevant local laws.
  • A due diligence statement is filed with geolocation data of the production plot.

The CDP Forests questionnaire and EUDR due diligence rely on the same underlying data: geolocation, volumes by origin, legal compliance, and deforestation free status. Building the EUDR data layer once produces a much stronger CDP Forests response with little additional work. Conversely, companies already disclosing to CDP Forests find their EUDR readiness already substantial.

Planning a multi year response

If 2026 is your first Forests cycle, plan in three steps:

Year 1: scope and screening. Identify all covered commodities in your operations and value chain, including indirect exposure through ingredients and packaging. Quantify volumes by commodity. Screen sourcing geography at country level. Publish or update an NDPE policy with cutoff date.

Year 2: traceability and certification. Map suppliers, mills, crushers, and production units for the highest risk commodities. Increase certified volume coverage with chain of custody. Start satellite or geolocation based deforestation monitoring for primary commodities.

Year 3: leadership. Reach production unit traceability for material commodities. Verify deforestation free volumes through independent monitoring. Run supplier engagement programmes with non compliance protocols and outcomes. Align with Accountability Framework Initiative methodology.

Where Dcycle fits

Forests data is the most fragmented of the three CDP modules: it lives in procurement systems, supplier portals, certification documents, and shipping records. Dcycle’s commodity and supplier modules pull this data into a single layer, structure it in CDP and EUDR compatible categories, and surface gaps before deadlines arrive.

If you would like to see how this would apply to your sourcing footprint, request a demo. For broader context on how Forests fits with CSRD and the wider regulatory ecosystem, the resource hub covers Climate, Water, and CDP scoring as well.

Final thought

Forests is the module where the gap between performance and disclosure is widest. Many companies have made significant progress on deforestation free supply but cannot evidence it at the granularity CDP requires. The 2026 cycle, especially with EUDR enforcement underway, is the year to close that gap. The data you build for one will increasingly serve both, and competitors that delay risk losing market access along with their score.

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