What’s next?

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 and related products is the only commodity that must not only be legal and deforestation-free, but also “degradation-free” under the EUDR.  

It is important to note that FSC certification does not exempt companies from their EUDR obligations.  

Selected derived products are outlined in Annex I of the Regulation. For instance, many wood, pulp, and paper products fall within the EUDR scope. With regards to rubber, new pneumatic tyres are part of the EUDR scope. The full Regulation is available here. 

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 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. 

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. 

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 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. 

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 Trace  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 Trace 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. 

This journey will help you understand which FSC Regulatory Module requirements apply to you and which offering you need based on your certification. Access it here. 

FSC Regulatory Module is a standard for voluntary use by organizations applying for or holding FSC certification to extend their certification scope 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 FSC-EUDR journey.