FSC and the EUDR: how are they connected?

The EUDR is approaching fast. From 30 December 2026, large and medium-sized companies must be able to submit a due diligence statement (DDS) for every consignment. For micro and small enterprises, the date is 30 June 2027 — with one important exception: products that were already covered by the annex to the old Timber Regulation (EUTR) do not receive that postponement. For virtually the entire timber sector, therefore, 30 December 2026 applies, regardless of company size. The dates have been postponed twice; for your own planning, always check the current status with the European Commission or RVO.

The question I receive most often: "We are FSC-certified, so aren't we simply ready?"

The short answer: no.

FSC certification is not an EUDR exemption

The EUDR does not recognise certification schemes. FSC® certification — however sound it may be — does not take over the legal obligation. The duty to carry out due diligence and to submit a DDS lies and remains with the operator itself. Only the competent authority — in the Netherlands the NVWA — determines whether you are compliant.

What FSC does provide: a substantial part of the evidence and the systematic approach on which you can build. Benchmarking by ASI has confirmed that FSC aligns strongly with the EUDR requirements (FSC). That saves work, but it is a starting point, not an end point.

What FSC offers in concrete terms

• FSC Regulatory Module — a voluntary add-on to your existing FSC certificate that translates the EUDR requirements into an auditable management system. Please note: the module has been re-published as nine separate addenda, including FSC-STD-40-004r for Chain of Custody. The earlier version remains valid until and including 31 December 2026 — the same week as the EUDR start date (FSC).
• FSC Risk Hub — country-level risk information, aligned with the EUDR benchmarking.
• FSC Trace — a free platform in which certificate holders share transaction data and supporting documents with their supply chain partners.

Please note: FSC Trace is not the EU system

I encounter this confusion regularly, and the names do not help. FSC Trace is a private platform operated by FSC. You submit your DDS in the European Commission's EUDR Information System, which runs on TRACES. These are two separate systems: being registered in FSC Trace does not mean any statement has been submitted. Whether a link or API between the two now exists is something to verify shortly before your implementation — matters on this point still change regularly.

What you can do now

The paperwork side is usually not the problem. Where things go wrong in practice is the data: geolocation data of the plots, origin information per consignment, and passing on DDS reference numbers through the supply chain. That must be operational before the end of December — not described, but working.

Are you stuck, or would you like to know whether your system will stand up to scrutiny? There is no EUDR certificate, but you can have your compliance assessed. I carry out annual internal EUDR audits and record who assessed what and when, with which scope, which findings and which follow-up — precisely the evidence a supervisory authority asks for.