Certification and the EU Deforestation Regulation: Helpful, But Not Enough

The EU Deforestation Regulation (EUDR) is reshaping how companies manage supply chain compliance. A common question we hear is: Is certification enough to prove compliance with the EUDR?

The short answer is no. Certification can support risk assessment and due diligence, but it cannot replace it. Under the regulation, operators remain fully responsible for ensuring that products are legal and deforestation-free.

What the Guidance Says

According to the official EUDR Guidance Document, Section 10, certification and third-party verification schemes can play a role in risk assessment and risk mitigation. The legal foundation is clear:

• EUDR Recital (52) and Article 10(2)(n) state that certification may provide useful information to support compliance.
  
  
• However, the use of certification is strictly voluntary.
  
  
• Most importantly, certification does not shift responsibility — operators must still exercise full due diligence.
  
  

In other words, certification is not a “green lane” into the EU market.

Where Certification Helps

Certification, such as FSC or PEFC, can provide valuable support in the compliance journey. It often delivers verified data on the legality of harvests and on sustainable forestry practices. Many schemes also include traceability systems, and in some cases, geolocation data, which is a core requirement under the EUDR.

By using certification, companies may also save time in their due diligence process. Verified certificates reduce the need to collect every piece of information from scratch and help streamline risk assessment. Beyond operational efficiency, certifications build customer trust by demonstrating commitment to sustainability and legal sourcing.

Why Assessment Is Key

Despite these benefits, certification alone cannot guarantee EUDR compliance. Different schemes vary widely in scope, audit quality, and credibility. Some allow mixing of certified and non-certified material within the supply chain — a practice explicitly not permitted under the EUDR.

That’s why the Guidance stresses the need for careful evaluation of any certification used in risk assessments. Operators must consider three dimensions:

• Standards: Does the scheme’s standard align with EUDR requirements, including the definition of “deforestation-free” and the cut-off date of December 31, 2020?
  
  
• Implementation: How robust are the audits? Are they carried out frequently, independently, and transparently?
  
  
• Governance: Does the scheme have strong oversight, stakeholder engagement, and safeguards against fraud or conflicts of interest?
  
  

Without this deeper review, certification risks becoming a false assurance, leaving operators exposed to compliance gaps and penalties.

The Takeaway

Certification should be seen as supporting evidence, not a compliance shortcut. It can strengthen EUDR due diligence by providing additional data, but it must always be combined with:

• Geolocation of production plots
  
  
• Supplier and trade documentation
  
  
• Independent verification where necessary
  
  

Only by combining certification with a structured due diligence process can companies meet the full requirements of the EUDR.

How 11Foundry Helps

At 11Foundry, we help companies go beyond paper certificates. With our Command Center™ platform, certifications can be integrated into broader EUDR workflows, ensuring they become part of actionable compliance evidence.

📩 To learn more, contact Katharina Schneider.