FSC Risk Assessment
The Forest Stewardship Council® (FSC®) provides a comprehensive framework to support organizations in identifying sourcing risks, documenting mitigation measures, and conducting risk evaluations aligned with the EU Deforestation Regulation (EUDR).
This page explains how FSC Risk Assessment (RA) frameworks support EUDR‑aligned due diligence—particularly for Asia‑Pacific suppliers serving EU-bound customers—and clarifies where responsibility remains with EU operators.
In Asia Pacific Regions, if you are sourcing from standard risk countries (i.e. Cambodia, Indonesia, Israel, Malaysia and Pakistan) and high risk countries (i.e. Democratic People's Republic of Korea and Myanmar), you will need to exercise a standard risk assessment according article 10.
EUDR Risk Assessment Requirements (Articles 9–11)
Under the EUDR, all in‑scope products must undergo a mandatory due diligence process that includes:
Information Collection (Article 9)
Operators must collect key information for all relevant products, including:
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Geolocation of production plots
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Supply chain details
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Evidence of legal and deforestation‑free origin
Risk Assessment
(Article 10)
All operators must evaluate risks based on:
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Supply chain complexity
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Presence of uncertified or mixed inputs
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Country or region benchmarking (low, standard, or high risk)
Risk Assessment is context‑dependent, not optional.
Risk Mitigation
(Article 11)
Where risks are not negligible, operators must implement documented and proportionate mitigation measures before placing products on the EU market.
Note:
All EU operators must submit a Due Diligence Statement (DDS) via EU TRACES, regardless of risk level.
How FSC Supports EUDR-Aligned Risk Evaluation
FSC provides a robust, auditable system that meets or exceeds many aspects of EUDR Article 10 risk assessment requirements. FSC certification can significantly support risk evaluation for APAC suppliers, especially in complex supply chains.
FSC Risk Assessment Framework
FSC’s certification-based approach helps organizations:
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Identify risks related to deforestation, legality, and unacceptable practices
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Apply a structured, indicator-based evaluation
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Ensure documented and auditable mitigation where risks exist
Learn more: FSC Aligned EUDR: Risk Assessment
Important notes
While FSC certification provides strong alignment with EUDR expectations, it does not replace EUDR due diligence or the legal obligations of EU operators.
Introducing FSC Risk Assessment
How this matters for APAC suppliers
When APAC FSC certificate holders supply materials to EU markets:
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Risk information must be verifiable and evidence-based, not declarative
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Gaps, inconsistencies, or weak mitigation may:
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Increase buyer risk classification
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Trigger enhanced due diligence by EU operators
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FSC risk assessment can support buyer due diligence, but:
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Does not determine EUDR compliance
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Does not replace Due Diligence Statement (DDS) submission
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Does not transfer legal responsibility
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FSC Risk Assessments & FSC Risk Hub
FSC Risk Assessment
Developed at national and sub‑national levels, FSC risk assessments help organizations evaluate:
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Country‑specific and regional risks
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Risks associated with composite products or materials of mixed/low‑risk origin
FSC Risk Assessment
FSC Risk Assessment
FSC Risk Assessment
FSC Risk Hub (Coming soon)
The FSC Risk Hub provides centralized access to:
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FSC Risk Assessments
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Relevant deforestation and legality risk data
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Continuous updates as new information becomes available
Understanding FSC Risk Assessments
FSC Risk Assessments help organizations evaluate the risks of sourcing forest materials, covering key topics such as environmental protection, human and labour rights, and High Conservation Values. These assessments follow the FSC Risk Assessment Framework (FSC‑PRO‑60‑006b), which provides consistent guidance for identifying risks and determining appropriate mitigation measures.
For users sourcing exclusively from FSC‑certified forests, the Simplified Risk Assessment Template offers a streamlined way to meet due‑diligence requirements with significantly reduced effort. Companies sourcing from non‑certified forests continue to use the full FSC Risk Assessment template under the FSC Regulatory Module. Together, the Framework and Simplified approach support credible, efficient, and responsible sourcing across supply chains.
The Simplified Risk Assessment addresses the limited gap between FSC certification and EUDR Article 10 requirements where allinputs are FSC-certified.
FSC Simplified
Risk Assessment
The FSC Simplified Risk Assessment is designed for supply chains where all inputs are FSC‑certified, addressing only the small remaining gap between FSC certification requirements and EUDR Article 10 expectations.
When it applies
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Only for FSC 100% or fully FSC-certified materials
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Suitable for low‑complexity supply chains with no non‑certified inputs
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Assumes that FSC Forest Management and Chain of Custody systems already manage:
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Deforestation risks
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Legality risk
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What it covers
The simplified approach focuses only on the remaining EUDR‑specific considerations not fully covered by FSC certification, such as: Risks linked to armed conflict or other contextual factors required by EUDR Article 10 Additional due diligence elements needed for EU operators to complete their assessment
FSC certification already delivers strong alignment with EUDR expectations.
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FSC Risk Assessment Framework
Where supply chains include any non‑certified inputs, a full Standard Risk Assessment is required.
When it applies
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Controlled Wood
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FSC Mix products containing Controlled Wood or other non‑certified components
What the Standard RA requires
Organizations must conduct:
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Comprehensive risk identification across all relevant FSC and EUDR-aligned indicators
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Documented risk mitigation measures where risks are not negligible
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Evidence that mitigation actions are both effective and verifiable
Why it matters
This approach aligns closely with EUDR expectations for enhanced scrutiny in: More complex supply chains Regions or sourcing contexts with elevated risk Products involving mixed or partially certified materials The Standard Risk Assessment ensures that all risks related to deforestation, legality, and unacceptable practices are addressed — supporting EUDR‑aligned due diligence for EU‑bound supply chains.
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