With the European Commission’s recent publication of initial country benchmarking assessments, an important milestone has been met in the implementation of the EU Deforestation Regulation (EUDR). Businesses should now be preparing themselves to move from developing due diligence systems to putting them into practice.
The benchmarking mechanism is a technical element of the EUDR, designed to support the regulation’s risk-based approach. The risk classification defines the extent of compliance checks that EU competent authorities perform on operators when sourcing from these 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 need to collect information, but not assess and mitigate risks.
The benchmarking therefore allows competent authorities to focus enforcement efforts where risks are higher and helps companies understand and fulfill their due diligence obligations. A country’s classification—whether low, standard, or high risk—guides how due diligence should be tailored, but it does not exempt operators from their responsibilities. Simplified due diligence still requires companies to assess the complexity of the relevant supply chain and risk of mixing with products from unknown origins or from standard/high risk countries, and to ensure that they are deforestation-free.
FSC underscores that due diligence remains essential for all country categories, including low-risk countries. 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 supply chain risk when implementing processes to comply with EUDR.
“This process is a necessary step towards operationalizing the EUDR,” said Matteo Mascolo, FSC’s EU Affairs Lead. “It’s important to remember that due diligence is required regardless of a country’s risk classification. Benchmarking helps tailor the process, but doesn’t remove the obligation. FSC can support companies every step of the way — from risk identification to traceability and mitigation — to ensure streamlined 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 FSC Aligned for EUDR — a voluntary, additional set of tools that help operators navigate compliance while reinforcing their sustainability commitments. This includes:
- Through core FSC certifications, companies already meet the strongest social and environmental protections in sustainable forestry and adhere to all applicable national legislation, verified through audits by independent accredited certification bodies.
- Supporting compliance through FSC's Regulatory Module, which translates complex regulatory requirements into a clear, practical standard to align supply chains with EUDR best practices.
- Investing in country-level risk assessments and publishing data through the FSC Risk Hub, designed to easily access completed FSC risk assessments.
- Enhancing supply chain traceability and transparency via development of FSC Trace
Next steps
The benchmarking process will be dynamic, with a first review scheduled for 2026. As a member of the EU Commission EUDR platform, FSC will engage in the process and support responsible sourcing in different countries.
As the EUDR moves from legislation to implementation, FSC remains committed to working with the European Commission, competent authorities, companies, NGOs, and other stakeholders to ensure robust, equitable, and transparent supply chains that protect the world’s forests.
EU commission resources
- General info: link here
- Eu commission methodology: link here
- Overview of country classification: link here
How to stay informed
For general interest, information on EUDR, and an overview of FSC's work, please visit fsc.org/EUDR
If you're a company ready to start implementing, or looking for more detail on FSC Aligned for EUDR, please visit the fsc.org/starteudr.
For more information on FSC Trace, please visit fsc.org/FSCTrace
More questions? Visit our FAQ page or send an email to EUDR@fsc.org.