EUDR: a step closer to implementation

With the recent release of initial country benchmarking assessments by the European Commission, a significant milestone has been reached in the implementation of the EU Deforestation Regulation (EUDR). Companies should now begin transitioning from developing due diligence systems to putting them into practice.

The benchmarking mechanism is a technical component of the EUDR designed to support the regulation’s risk-based approach. The risk classification determines the level of compliance checks that EU competent authorities will perform on operators sourcing from specific countries (1% for "low risk", 3% for "standard risk", and 9% for "high risk"). Sourcing from low-risk countries enables simplified due diligence, meaning that operators and traders must collect relevant information, but are not required to conduct risk assessments or mitigation.

Benchmarking allows competent authorities to focus enforcement where the risks are greater and helps companies understand and meet their due diligence obligations. A country's classification — whether low, standard, or high risk — guides the approach to due diligence but does not exempt operators from responsibility. Even simplified due diligence requires companies to assess the complexity of their supply chain, the risk of mixing with products of unknown origin or from standard/high-risk countries, and to ensure products are deforestation-free.

FSC emphasizes that due diligence remains essential across all country categories, including those classified as low risk. At the core of the EUDR is the obligation to assess and mitigate the risk of deforestation and forest degradation. FSC recognizes the importance of a proactive and informed approach to risk management when aligning supply chains with EUDR requirements.

“This process is a necessary step toward operationalizing the EUDR,” said Matteo Mascolo, FSC’s EU Affairs Lead. “It is important to remember that due diligence is mandatory regardless of a country’s risk classification. Benchmarking helps tailor the process, but it does not remove the obligation. FSC can support companies at every step — from risk identification to traceability and mitigation — to ensure effective compliance and meaningful progress in the fight against global deforestation and degradation.”

To support companies across all country classifications and with complex supply chains, FSC has launched the FSC Aligned for EUDR initiative — a voluntary, additional set of tools that helps operators navigate compliance while reinforcing their sustainability commitments. This initiative includes:

• Core FSC certifications, through which companies already meet the highest standards for social and environmental protection in sustainable forestry, as well as full compliance with relevant national legislation — verified through audits by independent, accredited certification bodies.

• Compliance support via FSC’s Regulatory Module, which translates complex regulatory requirements into a clear and practical standard, aligning supply chains with EUDR best practices.

• Investments in country-level risk assessments, and the publication of this data through the FSC Risk Hub, which enables easy access to completed FSC risk assessments.

• Enhanced supply chain traceability and transparency, through the development of FSC Trace, a tool designed to enable detailed tracking of product flows throughout the supply chain.

Next Steps

The benchmarking process will be dynamic, with the first review scheduled for 2026. As a member of the European Commission's EUDR platform, FSC will actively engage in the process and support responsible sourcing in different countries.

As the EUDR transitions from legislation to implementation, FSC remains committed to working with the European Commission, competent authorities, companies, NGOs, and other stakeholders to ensure strong, equitable, and transparent supply chains that protect the world’s forests.

EU Commission Resources Related to EUDR

• General Information and Partnerships: EU Green Forum – EUDR: Cooperation and Partnerships- Visit page
  Overview of activities, initiatives, and international partnerships related to EUDR implementation.

• Country Benchmarking Methodology: EU Commission Benchmarking Methodology – PDF Download. A document detailing the European Commission’s approach to country risk assessment under EUDR. Download PDF

• Overview of Country Risk Classification: (Note: The official overview is expected to be available through updated sources on the EU Green Forum or official EU Commission channels.)

How to Stay Informed

For general information about EUDR and an overview of FSC’s efforts, visit:
🔗 fsc.org/EUDR

If your company is ready to begin implementation or seeks more details about the FSC Aligned for EUDR initiative, visit:
🔗 fsc.org/starteudr

For more information on the FSC Trace traceability tool, visit:
🔗 fsc.org/FSCTrace

Still have questions?
Check our FAQ page or contact us at: EUDR@fsc.org