EU Regulation on Deforestation-free Products (EUDR)

While the EUDR is a European legislation, its implications are global. Companies placing or exporting the affected products in or from the EU market will have to conduct due diligence to confirm that the products have not been sourced from land which was deforested or degraded after 31 December 2020. Companies will also have to verify that these products are compliant with relevant legislation of the country of production, including respect for human rights, and the rights of affected Indigenous Peoples.

The EUDR applies to wood, rubber, palm oil, soy, beef, coffee, and cacao. Wood products, which are most connected to harvesting, have additional 'degradation-free' requirements.

If you are an FSC Certificate Holder and you would like to know if EUDR applies to you, you can search your product code in the FSC Product Classification & Harmonized System Alignment guidance document.

Access guiding document here

STEP 1: Create an inventory list of your commodities and/or products in scope

The EUDR places obligations on entities involved in the supply chain of covered commodities and products including wood, rubber, palm oil, soy, beef, coffee, and/or cacao. Wood is the only commodity that must not only be legal and deforestation-free, but also “degradation-free” under the EUDR.

If you are unsure about whether a derived product or material is included in the EUDR, selected derived products are outlined in Annex I of the Regulation. For instance, many wood, pulp and paper fall within the EUDR scope. With regards to rubber, new pneumatic tires are part of the EUDR scope. The full annex is available here.

If it is still unclear whether a product is in scope, we suggest evaluating each product against the following criteria:

1) Is the product made from one of the commodities covered?

2) Is the product  using one of the HS codes covered in Annex 1?

If the answer to both questions is yes, the product is covered. If the answer to either question is no, the product isn’t covered.

If you are FSC-certified, we would also recommend identifying which products are FSC-certified  and add both the HS Code and the FSC Product Code for these products. This additional exercise will help identify products that are potentially a risk due to being covered by the scope, but not yet FSC-certified.

STEP 2: Review the proposed requirements for FSC’s new Regulatory Module

FSC Regulatory Module is a standard for voluntary use by organizations applying for or holding FSC certification to extend their certification scope in order to align with EUDR due diligence obligations.

The FSC Regulatory Module sets the framework and requirements to:

• Introduce a due diligence system to support EUDR compliance, including information collection, risk assessment, and risk mitigation.
• Gather and transmit precise information on the origin of products (geolocation and time of production).
• Ensure that only deforestation-free materials enter FSC Chain of Custody.

The proposed additional requirements within the FSC Regulatory Module can be put in context by reviewing the info kit about the module here, and learning what requirements of the module apply to your unique organization based on ‘user type’ with our interactive user journey tool here: FSC EUDR (fsc-eudr-journey.org). 

STEP 3: Review your current Due Diligence system against EUDR requirements

The EUDR will require operators and traders of forest-based supply chains to conduct comprehensive due diligence before placing goods on the EU market.

While due diligence obligations will vary according to the level of risk a given country will be benchmarked by the EU Commission, if you have a current Due Diligence system in place, consider assessing it for alignment and gaps with EUDR requirements.

These include:

• Collecting and transmitting precise product information and supporting evidence including description, country of production, date and time range of production, and geolocation data for production.

• Evidence of Due Diligence actions and mitigation plans for identified risks.
• Report on Due Diligence steps taken, including how you may currently produce Due Diligence Statements (DDS) for competent authorities that verify a product's origin and compliance.

For FSC-certified companies, you will receive further clarity on DDS obligations within the Regulatory Module as well.

STEP 4: Collaboratively prepare with your supply chain

Your trading partners will need to provide your business with detailed information to fulfill EUDR reporting requirements. Start communicating early to flag the type of information you will be requesting from them in the coming months, help them understand the implications and value for their business, and troubleshoot any data or information gaps.

More detailed steps:

• Take inventory of currently available data for transactions involving forest-sourced materials such as wood, pulp, or rubber.

• Identify potential gaps in information you will be required to source from suppliers based on the known EUDR reporting requirements – such as origin of raw materials down to plot of land and time of harvest, sourcing practices, and production processes.
• Identify and support suppliers to source missing information.
• Identify any information that will require additional discussion and clarification with suppliers.
• Evaluate the current risk profiles that exists in your supply chain. Supply chains or markets that are currently high-risk can likely continue to be categorized as such when the EU’s new risk assessment launches. Consider preparing risk mitigation measures accordingly with your suppliers.
• If you are an existing FSC certificate holder, encourage your supply chain to consider certification and FSC Regulatory Model in order for all to benefit from the ability to get the REG+ invoice claim and promote your materials as deforestation free once your supply chain is fully verified.

STEP 5: Plan for secure data exchange with trading partners

Meeting EUDR requirements will benefit from robust traceability of transactions in relevant supply chains from source to end point. Trading partners must agree on transaction details like volume, product, origin plot of land, time of harvest, and species with one another – and their trading partners in turn, and so on – to ensure all materials have been sourced according to EUDR standards. They will also need to show evidence of social compliance such as adherence to Free, Prior and Informed Consent (FPIC).

Assess with your trading partners the process and technical platforms you will use to exchange and verify this transaction data. 

FSC is building a dedicated platform for FSC certificate holders called FSC Blockchain that will help facilitate this traceability requirement for participating certificate holders, amongst other benefits.

Built on blockchain technology, the platform enables participants to confidentially, flexibly, and efficiently access and exchange relevant data to assist with verification, due diligence and demonstrate conformity with evolving regulations.

FSC Blockchain will enable users to:

• Verify certification status of suppliers at the point of transaction. 
• Generate verified and traceable claims regarding products traded between yourself and trading partners. 
• Pass relevant data about the raw materials comprising FSC-certified products, such as geo-location of origin, time of harvest, species, product groups, and other essential information through the supply chain while maintaining confidentiality of trading partners.

STEP 6: Reach out about your intentions for EUDR compliance to your certification body

Certification bodies will likely experience a busy auditing period later this calendar year as the December deadline approaches. Reach out to relevant certification body now to express your intention to become EUDR compliant, and to confirm your plan to either use FSC EUDR Aligned with tools like FSC Regulatory Module and FSC Blockchain.

This communication can allow certification bodies to forecast demand for EUDR support and potentially assist with scheduling your audit during that demanding timeframe.

Don’t wait for the full picture to progress – plan ahead and beat the rush!

While more details of EUDR will emerge in the coming months, our current licence and certificate holders can progress on their journey to successful compliance and avoid a sprint to the December deadline.

We also encourage business who don’t currently hold an FSC certification to reach out and learn more about these solutions as a strong foundation that helps you to align with EUDR.

The FSC Regulatory Module and FSC Risk Assessment Framework comprise FSC Aligned Certification for EUDR, along with system-wide updates to strengthen FSC’s commitment to sustainable forestry.  These requirements ensure that our certification system remains robust and relevant in the evolving regulatory landscape. The Regulatory Module is relevant for companies that are in the scope of EUDR and companies that would like to support their current or future clients importing to European Union.

Download the FSC Aligned Certification for EUDR Fact Sheet

Watch the Introductory video for FSC Aligned Certification for EUDR 

FSC’s Regulatory Module supports FSC certificate holders in aligning their practices with Regulation (EU) 2023/1115 (EUDR) requirements and takes the guesswork out of compliance. The FSC Regulatory Module is a complementary standard to add on to existing FSC certification requirements for forest management, chain of custody, project certification, controlled wood and accreditation.

Due Diligence Requirements

The objective of due diligence for products in the FSC Regulatory Module is to demonstrate that the following conditions are met:

• Forest products are deforestation-free;
• they have been produced in accordance with the relevant legislation of the country of production;
• Forest products are covered by a due diligence statement.

Core elements of the additional due diligence requirements introduced in the module include:

• Information collection
• Risk assessment
• Risk mitigation

Download Regulatory Module

Regulatory Module Terms and Interpretations

In this document find all of the interpretations related to aligning the terminology between FSC and the EUDR. 

Download the Regulatory Module Explanatory Materials

Get started with the FSC Regulatory Module

Contact your certification body and request adding the FSC Regulatory Module to your
certification scope

The FSC Regulatory Module requires that risk assessment and mitigation is conducted with the FSC Risk Assessment Framework. FSC Risk Assessments assess the risk of sourcing material from supply areas and establish mitigation measures to address those identified risks. Companies can find mitigation measures from the assessment based on the framework.

The risk assessment is a document that contains indicators covering several key requirements for FSC such as High Conservation Values, human and labour rights, environmental protection, among others.

With 64 indicators for assessing risks connected to relevant social and environmental aspects, FSC’s Risk Assessment Framework is aligned with EUDR regulatory requirements to ensure responsible sourcing. It is valid for valid for both Regulatory Module users and Controlled Wood users. 

Download the FSC Risk Assessment Framework

Risk Assessment Template

FSC's Risk Assessment Template sets the foundation to assess and mitigate risk of sourcing from uncertified area.

To ensure all features of the template are enabled right click on the file before opening, selecting Properties, and then check the “unblock” button at the bottom of the popup. Learn more here about unblocking the macros here. 

If you have issues downloading the document or enabling the features contact country_requirements@fsc.org. 

Download the Risk Assessment Template

Quick Guide: Develop an FSC Risk Assessment

Review this summary on the main steps included when developing an FSC Risk Assessment.

Download the Risk Assessment Quick Guide

How to develop an FSC Risk Assessment

This supporting document provides guidance on how to use the FSC Risk Assessment Framework to develop or revise an FSC Risk Assessment. 

Download the Risk Assessment Infokit

Simplified Risk Assessment Template

Forest managers or for those sourcing only from FSC-certified forests can make use of FSC's Simplified Risk Assessment Template. 

Download the Simplified Risk Assessment Template

Organizations adopting the FSC Regulatory Module can make use of a Regulatory claim on sales documents for certified products signifying adherence to rigorous standards. When the whole supply chain is certified with the FSC Regulatory Module, certificate holders can make deforestation-free promotional statements.

FSC deforestation-free promotional statements

FSC Promotional Statements relating to EURD refer to the Regulation Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023. Also known as EUDR, the Regulation aims to ensure that a set of key products traded in the Union market and exported from the Union no longer contribute to deforestation and forest degradation. It repeals Regulation (EU) No 995/2010, also known as EUTR.

According to the above mentioned regulation ‘deforestation’ means the conversion of forest to agricultural use, whether human-induced or not;  ‘deforestation-free’ means that the relevant products contain, have been fed with or have been made using, relevant commodities that were produced on land that has not been subject to defore station after 31 December, 2020; and in the case of relevant products that contain or have been made using wood, that the wood has been harvested from the forest without inducing forest degradation after 31 December, 2020.

For more information, please visit our website: fsc.org/eudr