Understanding “FSC Aligned for EUDR”: Leveraging FSC’s New Framework to Reduce Deforestation and Achieve Compliance with EUDR
Companies worldwide are tightening operations and securing supply chains to comply with the European Union Deforestation Regulation (EUDR). Promoting sustainability and ethical sourcing, EUDR addresses deforestation associated with specific commodities — coffee, cocoa, rubber, palm oil, soy, beef, and wood. EUDR impacts growers, manufacturers, operators, and traders of these key commodities in the EU market and strives to prevent the import and export of products linked to deforestation and forest degradation.
Since EUDR entered the international scene in June 2023, companies have struggled to make sense of the relationship between relevant forest products and the world’s most renowned anti-deforestation certification program led by the Forest Stewardship Council® (FSC®). Both FSC and EUDR focus on reducing deforestation and managing products that are associated with forest degradation, but do they actually work together or reinforce one another — and if so, how? In direct response to these kinds of inquiries, FSC has recently launched a new framework designed to leverage their already robust FSC certification process to align with EUDR requirements.
Here we discuss some of the most frequently asked questions surrounding the overlap and interplay between EUDR and the newest framework from FSC known as “FSC Aligned Certification for EUDR”— an innovative set of solutions that provides a clear path to compliance from forest to product that work in concert with EUDR.
Brief History of FSC & EUDR
For thirty years, FSC has been advocating for resilient forests and forest communities around the globe, shedding light on the vital role of forests in our global ecosystem while establishing the world’s most rigorous certification program for forest-based products. And with the fast-tracking of responsible business practices that reduce deforestation mandated under EUDR, this important regulation is essentially building on three decades of FSC’s mission. EUDR effectively incentivizes companies to take accountability for their supply chains, create more transparent risk assessments, and submit annual reports to maintain eligibility to trade deforestation-free commodities within the European market.
Though distinct frameworks — one an international regulation and the other a voluntary certification program — EUDR and FSC share similar goals. FSC Aligned Certification for EUDR formally strengthens operability between FSC and EUDR by expanding the FSC’s existing certification program (FSC Certification - Forest Management & Chain of Custody Certification).
What is “FSC Aligned for EUDR”?
FSC Aligned for EUDR is a new streamlined framework designed by the Forest Stewardship Council to help connect the dots between the original FSC Certification and the EUDR, both of which already feature relevant overlaps and parallels.
The FSC Aligned for EUDR approach introduces two new elements that work in concert with the existing FSC Certification: FSC Aligned for EUDR Certification and the FSC Aligned for EUDR Reporting.
Supported by the FSC Risk Hub, the FSC Aligned Certification for EUDR includes voluntary add-on modules: FSC Regulatory Model and FSC Risk Assessment Framework. In this article, we focus specifically on the FSC Regulatory Model (shown in green on the left side of the infographic below).
What does the FSC Regulatory Module have to do with EUDR?
The FSC Regulatory Module (FSC-STD-01-004) is a voluntary standard of the FSC Aligned Certification for EUDR and includes accreditation and trademark requirements. It aims to demystify complicated requirements of the EUDR and simplify the compliance process for all users by translating EUDR obligations into FSC Certification requirements.
Specifically, the FSC Regulatory Module assists FSC certificate holders in aligning their operations with the requirements of Regulation (EU) 2023/1115 (EUDR), thus greatly reducing uncertainty regarding compliance. This module serves as a supplementary standard to enhance the existing FSC certification requirements for forest management, chain of custody, project certification, and controlled wood.
Is the FSC Regulatory Module required?
Given the differing levels of forest impact — based on a company’s operational activities or supply chain — FSC offers a voluntary approach to the Regulatory Module. As part of the FSC Aligned Certification for EUDR, the FSC Regulatory Module is available for organizations that wish to extend their FSC certification scope to align with the EUDR.
Is the FSC Regulatory Module customizable?
As mentioned above, the Regulatory Module offers further specifications designed to enhance forest management, chain of custody, and controlled wood certification.
Within the FSC Aligned Certification for EUDR, an organization may choose which product groups are included in the scope of the Regulatory Module. In an expansive list of frequently asked questions, FSC explains: For companies with both FSC-certified and non-certified products, the non-certified products would remain outside the FSC certification scope — and thus, outside the scope of the Regulatory Module — and are not assessed by the certification body. Consequently, such products selected to be outside the scope of certification could not be promoted as being in conformity with the FSC Aligned for EUDR requirements.
If your company has products that are outside the scope of the FSC Regulatory Module, SCS offers EUDR Verification & Validation Services. Our SCS program covers all affected commodities and is designed to provide confidence in your company’s EUDR compliance.
Which products can the Regulatory Module apply to?
The FSC Regulatory Module standard applies to wood, wood-based products, and rubber and can be used by organizations within and outside the EU. For organizations outside the EU, some requirements may not apply as outlined in Annex 1 of the FSC Regulatory Module (see page 41 of the FSC Regulatory Module official document).
It's important to note that while the FSC Regulatory Module is a voluntary add-on module only, once the certificate holder includes the Regulatory Module in its certification scope, the requirements become mandatory. For Forest Management certificate holders, these requirements then apply to all Management Units (MUs); for Chain of Custody users, certificate holders can choose which product groups it applies to.
Separate from the certification, the FSC Regulatory Module is a public tool that companies can use for their reference. This means any organization can reference the Risk Assessments associated with the Regulatory Module and apply them to any or all their relevant products without further assessment from a certification body.
The Regulatory Module can be used alongside existing certification types and includes accreditation requirements for certification bodies — for example, SCS Global Services is accredited to certify against the FSC’s Regulatory Model according to the specifications outlined within the Module.
How can I tell if my products are required to comply with EUDR and can be included in the FSC Regulatory Model?
If you are an FSC Certificate Holder already and looking to determine if and how EUDR might apply to your products, you can search the FSC Product Classification & Harmonized System Alignment guidance document within the FSC Document Centre. Note that this document includes all products affected by the EUDR. It does not distinguish those currently covered under the EU Timber Regulation (EUTR). Products covered by the EUTR have an extended transition timeline to move to the EUDR.
What are some of the benefits of the Regulatory Model of FSC Aligned Certification for EUDR?
As a whole, the FSC Aligned Certification for EUDR — including both the voluntary add-on Regulatory Module and the Risk Assessment Framework — offer four main benefits.
Compliance and credibility: the FSC Aligned Certification for EUDR is “purpose-built for accuracy,” says FSC, meaning that the entire framework is specifically aligned with EUDR requirements — thus removing the guesswork from the EUDR compliance process.
Mitigation and progress: FSC Aligned Certification for EUDR is thoughtful risk mitigation in action. This means that companies adhering to the FSC framework will be guided through compliance requirements for every aspect of the supply chain to ensure companies are aware of possible risks and are empowered to mitigate them.
Credible assurance: FSC leverages the power of independent, third-party verification to mobilize the FSC Aligned Certification for EUDR, offering an extra layer of credibility.
Natural progression: The original FSC Certification is already a world-renowned mitigation measure against deforestation — but now companies have the chance to build on their solid foundation in FSC with EUDR compliance requirements, too, by engaging the FSC Aligned Certification for EUDR.
What are the due diligence requirements associated with the FSC Regulatory Module?
FSC clarifies that for products covered by the FSC Regulatory Module, due diligence means demonstrating 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
How can I get certified to the FSC Aligned Certification for EUDR Regulatory Module?
If your company is already certified and opts to be verified against the voluntary add-on standard of the Regulatory Module, you can begin by requesting a scope extension from your certification body to include the FSC Regulatory Module. At a minimum, only a desk audit will need to be completed either during the next surveillance audit or as agreed with the certification body. If you are not yet certified to FSC standards, you can begin by requesting certification and noting that you wish to include the voluntary add-on module for EUDR. If SCS Global Services is your company's choice for FSC verification, you can reach out to us at [email protected].
It’s of vital importance to remember that even if your company becomes certified against the FSC Regulatory Module, this does not guarantee compliance with EUDR. Only the EU’s competent authorities hold the power to determine compliance with EUDR. That said, FSC has included additional requirements that can support the demonstration of compliance with EUDR. It’s best to work directly with your certification body to determine your company’s specific roles, responsibilities, and reporting requirements relative to EUDR.
Where can I learn more about the FSC Aligned Certification for EUDR, including more about the add-on Regulatory Module?
In addition to the official text of the FSC Regulatory Module, FSC has organized an exhaustive list of frequently asked questions (FAQs) on their website. The FAQs are the best place to get started learning more about the new FSC Aligned Certification for EUDR. On the same website, FSC has organized a list of resources such as videos, webinars, and fact sheets — plus the site offers downloadable one-sheets that summarize important details of different components of the FSC Aligned Certification for EUDR, including the Regulatory Model.
Need more help or have more questions? Please reach out to the SCS Global Services Forestry Team to get started: [email protected].
