Do you hold FSC or PEFC certification? Check whether this is sufficient to meet the EUDR requirements

“We’ve held FSC certification for years and pass our audits without any problems – surely that means the EUDR doesn’t apply to us?” We hear this question from companies in the timber and furniture sectors at almost every introductory meeting. The answer is shorter than one might hope: neither FSC nor PEFC certification exempts you from EUDR obligations – but it also doesn’t mean you have to build a due diligence system from scratch. The truth lies somewhere in between, and understanding exactly where the line is drawn allows you to realistically reduce the workload involved in implementation.

In this article, we explain what forest certification actually confirms, what it does not replace in the context of the EUDR, why the geolocation of plots is an additional requirement independent of certification, and how, in practice, to supplement FSC/PEFC documentation to meet the regulation’s requirements without duplicating work.

What an FSC or PEFC certificate actually confirms

FSC (Forest Stewardship Council) and PEFC (Programme for the Endorsement of Forest Certification) supply chain certification schemes are systems that verify the sustainable management of forests and the traceability of timber through the various stages of processing. In practice, the certificate confirms, amongst other things:

• that the timber comes from a forest managed in accordance with specific environmental and social standards,
• the continuity of the chain of custody between successive stages – from harvesting to the final product,
• the legality of the timber’s harvesting,
• in many cases – also elements of the risk assessment relating to the timber’s origin.

These are precisely the areas in which certification does indeed facilitate compliance with certain EUDR obligations, particularly the risk assessment stage described in Article 10 of the Regulation. The EUDR’s objective – to reduce deforestation and forest degradation – is, moreover, consistent with the mission of both organisations, which have been developing their own tools to support certificate holders for months.

What an FSC/PEFC certificate does NOT replace in the EUDR

This is where the most important part begins – something that certified companies often only realise during implementation. The EUDR requires three elements, none of which are automatically provided by any forest certification standard – not even the most rigorous:

1. The geolocation of a specific production plot. An FSC/PEFC certificate confirms that the timber originates from a forest managed in accordance with the standard, but does not automatically include the GPS coordinates of every plot from which a specific batch of raw material, destined for a specific product, was harvested. The EUDR requires precisely this – for plots up to 4 ha, at least one GPS point; for plots larger than 4 ha, a polygon defining their outline. This data is at the level of the delivery batch, not at the level of the overall certified forest holding.
2. A formal declaration confirming that no deforestation has taken place after 31 December 2020. The EUDR introduces a strict cut-off date – forest certificates do not always use exactly the same time limit, nor do they always explicitly refer to this specific criterion in the form required by the Regulation.
3. Submitting a DDS declaration via the TRACES system. Even a company that is fully compliant with the FSC/PEFC standard and has all the necessary documentation must submit an electronic due diligence declaration via the EU information system before placing the goods on the market. This is a purely procedural step which no certificate can carry out on the company’s behalf – and, as our implementation experience shows, the registration process itself can be a source of errors, regardless of how robust the company’s certification documentation is.

In other words: a certificate is strong evidence at the risk assessment stage, but in itself is not a substitute for the due diligence system required by the EUDR. The final decision on a product’s compliance with the regulation rests, in any case, with the competent national authorities, not with the certification body.

PEFC ST 2002-1:2024 – when certification goes one step further

It is worth noting that PEFC has developed a dedicated module of the PEFC ST 2002-1:2024 standard concerning the implementation of a due diligence system compliant with the EUDR. Holders of PEFC supply chain certification who implement this module may use the PEFC-EUDR declaration as evidence that they have exercised due diligence and demonstrated that there is no or negligible risk of non-compliance with the Regulation. PEFC-notified certification bodies carry out separate compliance audits in this regard – but even in this scenario, the final assessment of a product’s compliance with the EUDR remains the responsibility of the designated European authorities, not the certification body itself

FSC follows a similar approach, providing certificate holders with tools and data to support the assessment of deforestation risk and the verification of legal origin – but here too, the focus is on supporting the process, rather than automatically ‘fulfilling’ the EUDR requirements.

How to supplement your FSC/PEFC documentation with EUDR requirements – a checklist

If your company already holds a supply chain certificate, the steps below will enable you to build on that existing framework – rather than starting from scratch – to create a complete set of EUDR documentation:

1. Map the suppliers and production plots for which you currently hold certification, and check whether you have (or can obtain) the precise geolocation of each one – not just the general forest management area.
2. Check whether your certification body offers an EUDR module (e.g. PEFC ST 2002-1:2024 or equivalent FSC tools) – implementing such a module can significantly shorten the process of establishing a due diligence system.
3. Add EUDR clauses to your supplier contracts – including an obligation to provide GPS coordinates of plots, to update data when the harvesting location changes, and to provide a formal declaration confirming that no deforestation has taken place since 31 December 2020.
4. Develop an internal risk assessment procedure that uses certification data as one of its sources, but supplements this with the country/region of origin risk classification published by the European Commission.
5. Register your company with the TRACES NT system and prepare to submit DDS declarations – certification does not exempt you from this administrative step.
6. Retain documentation for the required 5 years, combining certification evidence with geolocation data and copies of submitted DDS declarations – in the event of an inspection, the authorities will expect a coherent set of documents, not just the certificate itself.

When does certification actually simplify compliance, and when does it not?

A certificate is most helpful when:

• the supply chain is already well documented and traceable down to plot level,
• the certification body has implemented a dedicated EUDR module (such as PEFC ST 2002-1:2024),
• the company works with regular suppliers from low- or standard-risk countries, where certification data is up to date and complete.

A certificate alone is not sufficient, and additional work is required when:

• the supply chain involves many small, frequently changing suppliers – a situation typical, for example, in the import of cocoa, coffee and palm oil, where RSPO or Rainforest Alliance certification faces similar limitations to those of FSC/PEFC in the timber industry,
• the certificate covers a general area of forest management rather than specific, geolocated plots for individual consignments,
• the goods originate from a region classified as standard or high risk for deforestation – in such cases, regardless of certification, an in-depth risk assessment and additional documentation are required.

Frequently Asked Questions

Does an FSC certificate alone exempt a company from registering with the TRACES system?
No. Registration with TRACES and the submission of a DDS declaration are separate, mandatory procedural steps required by the EUDR, regardless of any certification held.

Do I need to have the geolocation of each plot, even if I hold an FSC certificate for the entire forest area?
Yes – the EUDR requires geolocation at the level of the specific plot from which a given batch of raw material used in a product placed on the market originates, regardless of the scope of the certification.

Is it worth implementing PEFC ST 2002-1:2024 if a company already holds PEFC certification?
In many cases, yes – this module allows you to use your existing certification scheme as the basis for your EUDR due diligence system, which can shorten implementation time and reduce duplication of documentation. The final decision should take into account the structure of your supply chain and the countries of origin of the raw material.

Let’s work together to identify where your certificate ends and your EUDR obligations begin

We help companies holding FSC and PEFC certificates to identify exactly which elements of documentation are missing for full compliance with the EUDR – without having to build a due diligence system from scratch and without duplicating audit work that has already been carried out. Contact us to find out how this applies to your situation.