To begin preparing for compliance with the EU Deforestation Regulation (EUDR), start by identifying which of your products fall under the scope of the Regulation.

Determine if a Product is in Scope

For each product you handle, ask the following two questions:

Question 1 :

Is the product made from a covered commodity?

Covered commodities under the EUDR include:

• Wood
• Rubber
• Palm oil
• Soy
• Beef
• Coffee
• Cacao

Question 2 :

Is the product classified under an HS code listed in Annex I of the Regulation?
You can check using the FSC Product Classification & HS Code Alignment Guidance here.

If the answer to both questions is yes, then the product is considered in scope under the EUDR.
If the answer to either question is no, the product is not in scope.

Important Notes :

• FSC certification does not exempt you from your obligations under the EUDR.
• Wood and wood-based products are subject to an additional requirement: they must be not only legal and deforestation-free, but also degradation-free.
• Many wood, pulp, and paper products fall within the EUDR scope.
• For rubber, products like new pneumatic tyres are explicitly included.

Resources :

• Full Regulation (EU) 2023/1115: Access it here
• FSC Product Classification & HS Code Alignment Guidance: Access it here

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:

Gathering and transmitting accurate information, including:

• Product description
• Country of production
• Date or time range of production
• Geolocation data for all areas where production occurs

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Evidence of Due Diligence actions and mitigation plans for identified risks.

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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.

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For FSC-certified companies: Additional guidance on DDS obligations will be provided in the FSC Regulatory Module.

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 exist 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.

Access these components today: 

• FSC Regulatory Module here

• FSC Risk Assessment Framework here

You can already start developing your risk assessment using the FSC Risk Assessment Framework. This requires the use of the Risk Assessment Template, which helps establish risk assessment and mitigation measures. Learn about how to use the Risk Assessment Template following this guidance. In addition, we have an available playlist for a video tutorial series which can be found on YouTube here. 

FSC is in the process of revising existing risk assessments for 40 prioritized countries. The work will continue in 2025 and beyond until 90 countries are completed by 2027. Keep track of these assessments here. 

Not every certification body may offer the FSC Regulatory Module from day one, so contact your certification body proactively about the FSC Regulatory Module.

Certification bodies will likely experience a busy auditing period later this calendar year as the December deadline approaches, and there is currently a global auditor shortage. Reach out to relevant certification body now to express your intention to become EUDR compliant, and to confirm your plan to use FSC Aligned for EUDR. 

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

If you plan to use FSC Trace, you can already download our data sheets from fsc.org/FSCTrace and start preparing your data on products and trading partners. When the platform launches for licence holders, you will be ready to start uploading your data.