Certification and EUDR — FSC, PEFC, and Compliance

Certification and EUDR Compliance

One of the most frequently asked questions about EUDR is: "If my products are FSC/PEFC certified, am I automatically compliant?" The short answer is no. But certifications play an important role.

The Essential Principle: Certification Does Not Replace Due Diligence

Article 10(2) of Regulation (EU) 2023/1115 explicitly states that certifications and other third-party verification schemes may be used as an element of the risk assessment, but are not sufficient in themselves to demonstrate EUDR compliance.

This is because EUDR imposes specific requirements (geolocation, the 31 December 2020 cut-off date, compliance with the full national legislation) that are not necessarily covered by all certification schemes.

What Certifications Can Provide

Recognized certification schemes can contribute to several aspects of the due diligence system:

Aspect	Certification Contribution
Legality of harvesting	FSC and PEFC verify compliance with the forestry legislation of the country of production.
Traceability	Chain of Custody systems provide traceability from source to final product.
Forest management	Forest management certification confirms sustainable practices on certified plots.
Independent audits	Certification schemes include periodic audits by independent third parties.

What Certifications Do NOT Sufficiently Cover

• EUDR-specific geolocation — not all certification schemes collect GPS data in the format required by EUDR (geolocation requirements).
• The 31 December 2020 cut-off date — certification does not automatically guarantee that the land was not deforested after this specific date.
• Compliance with all national legislation — EUDR requires compliance with legislation on land use rights, environmental protection, labor rights, indigenous peoples' rights, tax legislation, anti-corruption rules, etc. Certifications typically cover a subset.
• The due diligence statement — regardless of certifications, the operator must submit a statement in the EU Information System.

Key Relevant Certification Schemes

FSC (Forest Stewardship Council)

The most widely used forest certification scheme globally. FSC has announced updates to its standards to align with EUDR requirements, including the collection of geolocation data. Products with FSC Forest Management certification (FSC FM) offer a higher level of assurance than those with Chain of Custody certification alone (FSC CoC).

PEFC (Programme for the Endorsement of Forest Certification)

The umbrella scheme that endorses national forest certification systems (e.g., SFI in North America, AFS in Australia). PEFC is also working on aligning its standards with EUDR requirements.

Other Relevant Schemes

• RSPO (Roundtable on Sustainable Palm Oil) — for palm oil.
• Rainforest Alliance — for cocoa, coffee, and other tropical products.
• RTRS (Round Table on Responsible Soy) — for soy.

Practical Recommendations

1. Maintain existing certifications — they are a valuable element of the risk assessment and can significantly reduce the due diligence effort.
2. Do not rely exclusively on certifications — supplement with the specific data required by EUDR (geolocation, post-2020 verification).
3. Check for scheme updates — FSC, PEFC, and other schemes are adapting their standards. Updated versions may cover more EUDR requirements.
4. Document the certification contribution within the risk assessment — clearly explain which aspects are covered by the certification and which require additional verification.

For a general overview of all compliance requirements, see the EUDR compliance checklist.