FSC Regulatory Module

Introducing the FSC Regulatory Module

What is the new FSC Regulatory Module?
The all new add-on FSC-STD-01-004 FSC Regulatory Module is a complementary standard designed for voluntary use by organisations applying for or holding FSC certification to extend their certification scope in order to align with the EUDR (Regulation (EU) 2023/1115).

It includes accreditation and trademark requirements and is available for:
- Forest Management certification,
- Chain of Custody certification,
- Project Certification,
- Controlled Wood.
The module outlines robust due diligence systems, conducting thorough risk assessments with FSC’s Risk Assessment Framework, and maintaining transparent supply chain documentation.

The FSC Regulatory Module sets the framework and requirements to:
- introduce a due diligence system to support EUDR compliance, including information collection, risk assessment and risk mitigation,
- gather and transmit precise information on the origin of products, including geolocation and time of production, and
- ensure that only deforestation-free material enters the FSC chain of custody.
What are the additional due diligence requirements?
The FSC Regulatory Module outlines the due diligence requirements for all users.

Core elements of the additional due diligence requirements introduced in the module include:
- Information collection
- Risk assessment
- Risk mitigation
The objective of due diligence for products in the FSC Regulatory Module is to demonstrate 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.
How much does the FSC Regulatory Module cost?

FSC is providing this add-on module to FSC certificate holders on a complementary basis (no additional charge by FSC). However, please check with your certification body for any costs relating to assessment against this additional add-on standard.
How to navigate the FSC Regulatory Module and where to start?

FSC International has prepared explanatory materials, customised for you and your journey towards EUDR compliance.

Click on the link below to access the interactive user journey tool.

Get started
What are the relevant dates for implementation of the FSC Regulatory Module?

Approval date: 05 June 2024

Publication date: 1 July 2024

Effective date: 1 July 2024

Further details can be found here.

What EUDR is asking you & FSC Regulatory Module

What EUDR is requiring is reflected in the FSC Regulatory Module (FSC-STD-01-004), which is divided into the following parts:

Part 1	Additional requirements for Forest Management certification
Part 2	Additional requirements for Chain of Custody certification
Part 3	Additional Trademark requirements
Part 4	Additional Accreditation requirements
Annex 1	Requirements not relevant to Organisations not in Scope of EUDR
Annex 2	Due Diligence Statement
Annex 3	Indicators for Risk Assessment

Overview of due diligence requirements for Forest Management (FM)

Due diligence (DD) is exercised on the products covered by the scope of FSC-STD-01-004 FSC Regulatory Module prior to selling the product as conformant with it, in order to demonstrate that the product:

is deforestation-free; and
has been produced in accordance with the relevant legislation of the country of production.

Simplified DD or Full DD?

* Risk benchmarking by EU Commission of each country: Low, Standard or High risk

With the Simplified Risk Assessment Template, the main obligation of Organisations would be to collect the relevant information about what they are already doing under FSC certification, that can then be sent through the supply chain.

The Simplified Risk Assessment Template is also available for companies sourcing solely from FSC-certified forests; assuring that the additional work required to demonstrate due diligence is drastically less.

Users of the FSC Regulatory Module not sourcing from FSC-certified forest must use the full FSC Risk Assessment template. Learn more about how to use an FSC Risk Assessment to conform with the FSC Regulatory Module here.

[The above briefly describes the FSC Regulatory Module obligations relating to FM. Please refer to FSC-STD-01-004 FSC Regulatory Module for full and complete details]

Download the Simplified Risk Assessment Template

Regulatory claims

Organisations adopting and who conforms to the FSC Regulatory Module, can make use of a “Regulatory” or “REG” claim on sales documents for certified products signifying adherence to rigorous standards.

“Regulatory” or “REG” claim made on sales and delivery documents is used in combination with the FSC claim (excluding FSC Recycled), for products based on inputs exclusively of material which has been assessed to be in conformity with the requirements of FSC Regulatory Module.

Products exclusively made of input materials from a fully verified supply chain (i.e. every upstream certificate holder within the chain) can add a plus symbol to the Regulatory claim, i.e., Regulatory+ or REG+

Regulatory output claim	Eligible inputs	FSC control system
Regulatory output claim	Eligible inputs	Transfer	Percentage	Credit
Regulatory+ or REG+	Regulatory+	ü	N/A	N/A
Regulatory or REG	Regulatory+, Regulatory, material in conformity with the FSC Regulatory Module	ü	ü	ü

When the whole supply chain is certified with the FSC Regulatory Module, certificate holders can make deforestation-free promotional statements. Learn more.

How to add FSC Regulatory Module to your certification scope?

Review the FSC Regulatory Module requirements

Download FSC Regulatory Module standard (FSC-STD-01-004)

Reach out to your certification body

Let your certification body know that you wish to add the FSC Regulatory Module to the scope of your existing FSC certification as soon as possible.

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

Support a desk audit by your certification body

The certification body shall assess your conformity with the applicable requirements of the FSC Regulatory Module, at minimum as a desk-based evaluation, prior to extending the scope of certification.

Note: The assessment may be conducted at the regular time scheduled for the next scheduled evaluation or earlier as agreed with the client.

New regulatory FSC claims

Once the FSC Regulatory Module is included in your FSC certification scope, you have an option to make new regulatory FSC claims.

You can still use the usual FSC claims, however using the new regulatory FSC claims (“Regulatory/REG”) lets your clients know that your organisation has been audited against the new FSC Regulatory Module, supporting compliance with EUDR.

A fully verified supply chain is where every certificate holder has applied the FSC Regulatory Module and establishes a product group for the purpose of controlling the “Regulatory+/REG+” output claim.

This claim can be passed on along the supply chain by certificate holders according to the requirements of this standard.