FSC Risk Assessment Ukraine V3-0: effective immediately, no transition period

On 14 August 2026, FSC® International published a revised national risk assessment for Ukraine: version V3-0. The assessment has been aligned with the new FSC Risk Assessment Framework and replaces V2-0.

Please note the effective date: the assessment applies as of 14 August 2026, immediately and without a transition period. There is therefore no period during which you may still apply V2-0. Anyone with Ukrainian material in their supply chain must work with V3-0 from now on.

What is changing: from zones to source types

The main substantive change lies in the methodology. Whereas the previous version worked with subnational risk zones based on administrative boundaries, V3-0 treats Ukraine as a single sourcing area subdivided by source type. Risk classification and control measures therefore follow the actual sourcing circumstances rather than provincial boundaries.

FSC distinguishes four source types:

• Government-controlled area
• Forests with radioactive contamination
• Forests with explosive ordnance contamination
• Temporarily occupied territory
• soort

For temporarily occupied territory, the outcome remains unchanged: sourcing from these areas continues to be excluded. For the government-controlled area, FSC assesses a number of indicators — including child labour, forced labour, freedom of association, discrimination, gender equality and forest conversion — as negligible risk. This may considerably simplify your control measures, provided you can substantiate the source type for each shipment.

What this means for your organisation

If you have controlled wood within your scope and Ukrainian timber occurs in your supply chain — including indirectly, via a supplier further up the chain — this directly affects your due diligence system.

• Update your risk assessment and control measures to V3-0; references to V2-0 in your procedures are outdated with immediate effect.
• Ensure that you can determine the relevant source type for each supplier or shipment. This is now the decisive variable, no longer the region.
• Document the supporting evidence. At your next audit, due diligence will be assessed against V3-0.

Also usable for your EUDR substantiation

The risk assessment has been drawn up within the FSC system, but the underlying analysis can also be used as supporting evidence for your EUDR due diligence. An important point to keep in mind: FSC certification is not an EUDR exemption. The EUDR does not recognise certification schemes, and the obligation to submit a due diligence statement remains with you as the operator. V3-0 provides evidence and structure, not an indemnity.

Source: FSC.org — New risk assessment strengthens responsible sourcing in Ukraine

Would you like to know whether your due diligence system is ready for the transition to V3-0? In a short, no-obligation conversation, we will look together at where adjustments are needed. [More about EUDR compliance checks →](/eudr)