Timber certification

certification as a tool in due diligence

The EU Deforestation Regulation (EUDR) does not recognise certification as an automatic proof of compliance. Operators remain responsible for exercising due diligence and demonstrating that products placed on the EU market are:

• legal;
• deforestation-free and forest degradation-free after 31 December 2020;
• associated with no more than a negligible risk of non-compliance.

However, third-party certification can provide valuable information and verification mechanisms that support due diligence obligations and help operators assess and mitigate risks.

ATIBT has published practical guidance on the role of certified tropical timber supply chains in supporting compliance with the EU Deforestation Regulation (EUDR). The publication highlights how certification can contribute to traceability, legality verification, risk assessment and risk mitigation by providing reliable information, independent audits and documented chain-of-custody systems. However, it also stresses that certification does not replace EUDR due diligence. Operators remain responsible for collecting information, assessing risks, implementing mitigation measures where necessary and demonstrating that the risk of non-compliance is negligible before placing products on the EU market.

How certification supports EUDR compliance

Certification schemes can contribute to the three main pillars of the EUDR:

1. Traceability and geolocation

Certified supply chains generally provide:

• traceability from forest to export product;
• documented chain-of-custody systems;
• identification of harvesting areas and forest concessions;
• georeferenced Annual Cutting Areas (ACAs);
• harvesting information and batch tracking systems.

These systems can facilitate the collection and verification of information required under Articles 9 and 10 of the EUDR

2. Legality

Certification audits typically assess compliance with:

• harvesting rights;
• environmental requirements;
• labour obligations;
• community and Indigenous Peoples' rights;
• trade and taxation requirements.

Certification therefore provides additional assurance through independent audits, document reviews, field inspections and grievance mechanisms.

3. Deforestation and forest degradation risk

Certified forest management systems often include:

• long-term management plans;
• forest inventories;
• monitoring of harvesting activities;
• protection of High Conservation Value areas;
• controls on forest conversion;
• environmental monitoring procedures.

These elements can help operators demonstrate that harvesting activities are consistent with sustainable forest management practices and support their risk assessment under the EUDR.

What information can certified suppliers provide?

Depending on the certification scheme and scope, certified operators may be able to provide:

• geolocation data and harvesting area references;
• forest concession information;
• management plans;
• chain-of-custody documentation;
• harvesting permits and transport documents;
• audit reports and corrective action records;
• FSC®, PEFC/PAFC™ or legality certificates;
• information relevant to EUDR risk assessment and mitigation.

Important limitation

Certification does not replace due diligence.

Under the EUDR, operators remain responsible for:

1. collecting information;
2. assessing risk;
3. implementing risk mitigation measures where necessary;
4. concluding that the risk is negligible before placing products on the EU market.

Certification should therefore be considered as one element of evidence within a broader due diligence system rather than a substitute for EUDR obligations.

Forest Certification

Forest certification is a market-based instrument and a voluntary process whereby an independent third party (the “certifier”) assesses the quality of forest management and production against a set of requirements (“standards”) predetermined by a public or private certification organization. Forest certification, and associated labelling, is a way of informing consumers about the quality of the forests’ management from which wood and other forest products were produced. It is implemented through two separate but linked processes:

1. forest management certification which assesses whether forests are being managed according to a specified set of standards (sustainable and/or legal); and
2. chain of custody certification (sometimes referred to as CoC certification), which verifies that certified material is identified or kept separate from non-certified or non-controlled material through the production process, from the forest to the final consumer.

To label an end-product as certified, both forest management certification and chain-of-custody certification are required.

Seven common certification systems are explained here briefly on how they could facilitate a due diligence process, and how the scheme is adapted to EUDR regulation’s requirements. For the framework of this portal we differentiate between sustainable forest certification systems and timber legality verification systems and include here most relevant and active systems: