PEFC ST 2002-1:2024

Requirements for the Implementationof PEFC EUDR Due Diligence System(PEFC EUDR DDS)PEFC
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Copyright notice© PEFC Council 2024
This standard is protected by copyright owned by the PEFC Council. The document is freely available
from the PEFC Council website www.pefc.org or upon request.
No part of this standard may be changed or amended, reproduced, or copied, in any form or by anymeans for commercial purposes without the permission of the PEFC Council.
The official version of the document is in English. Translations of the document can be obtained fromthe PEFC Council or PEFC National Governing Bodies. When there is doubt in regard to language
interpretation, the English version is the reference.

Document name: Requirements for the Implementation of PEFC EUDR Due Diligence System
Document title: PEFC ST 2002-1:2024
Approved by: PEFC General Assembly

Date: 2024-07-20

Issue date: 2024-07-20
Date of entry into force: 2024-07-20

PEFC ST 2002-1:2024 - Requirements for the Implementation of PEFC EUDR Due Diligence System

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Contents
1.

Scope ...................................................................................................................................................... 7

2.

Normative references ............................................................................................................................ 7

3.

Terms and definitions ........................................................................................................................... 8

4.

PEFC EUDR Due Diligence System (DDS) requirements ................................................................ 16
4.1

General ............................................................................................................................................... 16

4.2

Additional management system requirements ................................................................................... 17

4.3

Additional requirements for the identification of input material ........................................................... 17

4.4

Additional requirements for the declaration of outputs ....................................................................... 18

5.

Collection of information .................................................................................................................... 19
5.1

6.

General ............................................................................................................................................... 19
Risk assessment ................................................................................................................................. 21

6.1

General ............................................................................................................................................... 21

6.2

Assessment of the risk that relevant products are sourced from activities where
deforestation and/or forest degradation occurred after 31 December 2020....................................... 23

6.3

Assessment of the risk that relevant products are sourced from activities not complying
with relevant legislation of the country of production .......................................................................... 24

6.4

Assessment of the risk that relevant products are sourced from activities where the capabilityof the forest to produce a range of wood and non-wood forest products and services on asustainable basis is not maintained or harvesting levels exceed a rate that can be sustainedin the long term, or genetically modified trees occurred. .................................................................... 26

6.5

Assessment of the risk that relevant products are mixed with controversial sources
and/or non-compliant products at supply chain level .......................................................................... 27

7.

Substantiated concerns ...................................................................................................................... 28

8.

Risk mitigation ..................................................................................................................................... 29
8.1

General ............................................................................................................................................... 29

8.2

Requiring additional information, data and documents ...................................................................... 29

8.3

Audits .................................................................................................................................................. 30

8.4

Corrective measures ........................................................................................................................... 30

9.

Due diligence statement submission and publication .................................................................... 31
9.1

Due diligence statement submission .................................................................................................. 31

9.2

Due Diligence System report and publication ..................................................................................... 31

10.

No placement on the market .............................................................................................................. 33

Appendix 1 (normative), Content of the Due Diligence Statement, as per Annex 2 of the EUDR ........ 34

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Foreword
PEFC, the Programme for the Endorsement of Forest Certification, is a worldwide organisation promoting
sustainable forest management through forest certification and labelling of forest and tree-based products.
PEFC certified sustainable forest management works through the PEFC endorsement of national andregional forest certification systems, which were independently assessed to be in compliance with PEFC’s
sustainability benchmarks for forest management certification standards. For further information on PEFC’s
sustainability benchmarks, please see the PEFC website at www.pefc.org.
PEFC chain of custody certification is based on PEFC ST 2002, Chain of Custody of Forest and tree-based
products. PEFC ST 2002 delivers confidence that forest and tree based material in products with the PEFC
claim or label originates in PEFC certified sustainably managed forests, recycled material and/or PEFC
controlled sources.
Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making
available on the Union market and the export from the Union of certain commodities and products associatedwith deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (EUTR), hereinafterreferred to the European Deforestation Free Regulation (EUDR), or EUDR, or the regulation, entered into
force on 29 June 2023. The objective of the regulation is to ensure that products made from commodities
under the scope of the regulation shall not be placed or made available on the Union market or exported
from the Union market, unless all the following conditions are fulfilled: they are deforestation-free; have been
produced in accordance with the relevant legislation of the country of production; and are covered by a due
diligence statement, with associated geolocation data and evidence.
PEFC ST 2002-1:2024 is an optional, module standard that PEFC chain of custody certified organisations
can add to their existing PEFC chain of custody certification scope to support their effort in demonstrating
their compliance with EUDR.
This module standard was developed in an open, transparent, consultative and consensus based process
covering a broad range of stakeholders, following PEFC’s procedures for the development of technicaldocumentation outlined in PEFC GD 1003:2009.

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4Introduction
PEFC has developed the module standard, PEFC ST 2002-1:2024, to support organisations indemonstrating compliance with the EUDR. It comprises the requirements for the implementation of a PEFC
EUDR adapted Due Diligence System (PEFC EUDR DDS).
This document is not a standalone but a voluntary, module standard to be used in addition to the PEFC
Chain of Custody standard.
To ensure compatibility with the Due Diligence System described in the PEFC Chain of Custody standard,
and that any material going through the PEFC EUDR DDS results in no or negligible risk in coming fromcontroversial sources, the PEFC EUDR DDS module standard covers requirements to eliminate the risk ofcontroversial sources as defined by the PEFC Chain of Custody standard (for those aspects where thePEFC chain of custody DDS goes beyond EUDR) and of non-compliant products as defined by the EUDR, at
the origin and at supply chain level.
PEFC chain of custody certificate holders certified against this module standard can use the PEFC-EUDR
claim to demonstrate that required information has been obtained and that due diligence has been exercisedand has shown no or negligible risk of non-compliance with the EUDR.
PEFC notified certification bodies will conduct the third-party conformity assessment audits of theorganisation against this module. However, the final decision on EUDR compliance of the relevant productlies with the designated competent authorities of the European Member States.
By implementing this module standard, PEFC chain of custody certificate holders not only strengthen theircommitment to environmental and social responsibility but also contribute to the global goal of halting
deforestation and forest degradation.
How to find applicable requirements:
The PEFC EUDR DDS module standard, PEFC ST 2002-1:2024, can be used by any organisation within theforest and tree based supply chain, independently of geographical location, type and size of organisation.
For organisations based inside the European Union territory and subject to the EUDR, the EUDR establishes
different requirements depending on the type of organisation (operator and trader) and the size classification(SME and non-SME). The PEFC EUDR DDS module standard accounts for this differentiation by specifying
the type of organisation and classification in its requirements, where relevant. To minimise risks and facilitate
the implementation of the PEFC EUDR DDS by other organisations further down the supply chain, SME
organisations are still subject to certain requirements under the PEFC EUDR DDS module standard, even if
the EUDR does not require it.
For organisations based outside the European Union territory and not subject to the EUDR, but with relevant
products that are part of the Europe-bound supply chain, the organisation type and size classification isirrelevant. The PEFC EUDR DDS requirements shall apply to them when they are indicated as ‘theorganisation’, as defined in 3.24 of the standard.

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Table 1: Overview of requirements according to the classification of organisations by the EUDR

SME
operator

Non-SME
operator

SME
traderNon-SME
trader

Chapter

Requirements

Chapter 8

Risk mitigation measures shall include
model risk management practices,
reporting, record-keeping, internal control
and compliance management, including
the appointment of a compliance officer atmanagement level

X

X

Chapter 8

Implement an independent audit function tocheck the internal policies, controls andprocedures

X

X

Chapter 9

Due diligence statement submission

X

X

Chapter 9

Public reporting on Due Diligence System’s
information

X

X

X

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1.

Scope

This standard describes the steps that PEFC chain of custody certified organisations may follow to
implement a Due Diligence System towards demonstrating EUDR compliance using the PEFC scheme andissue PEFC-EUDR claims. The responsibility of compliance with the EUDR remains fully with theorganisation.
This document is a module standard, to be implemented on a voluntary basis, at the global level, by anyorganisation applying for or holding a PEFC recognised chain of custody certificate.
Before making PEFC-EUDR claims, the organisation shall extend the scope of its PEFC chain of custodycertificate to cover the PEFC EUDR DDS module standard.
The standard applies to relevant products made with forest and tree based materials.
The standard can be used by an organisation defined as an operator and/or trader who places or madeavailable forest and tree based material and/or products on the Union market and/or exports from the Union
market. It also can be used by an organisation based outside the European Union territory that does notdirectly place or make available forest and tree based material and/or products on the Union market or
export from the Union market, but the material or product will finally be placed or made available on orexported from, the Union market.
The PEFC EUDR DDS described in this voluntary module standard is to be used instead of the regular DDS
described in chapter 7 and appendix 1 of PEFC ST 2002 for the PEFC product group(s) to which the PEFC
EUDR DDS standard is applied. Moreover, this voluntary module standard includes additional definitions andadditional requirements for management systems, identification of inputs, and declaration of outputs. Anyother requirements of the PEFC Chain of Custody standard remain valid.
If an organisation uses both the PEFC ST 2002 DDS and the PEFC EUDR DDS established in thisdocument, the organisation shall define at the product group level which DDS is implemented.
Forest and tree based material entering a PEFC product group for which this standard is implemented shallhave gone through the PEFC EUDR DDS and resulted in no or negligible risk, independently as to whether it
is PEFC certified material or not.
Where an EUDR source is referred to within the document, it is indicated in brackets, and refers to the EUDR
Regulation, followed by the Article number, and, where applicable, by the Paragraph number or letter, as
corresponds (EUDR, Article number, Paragraph number or letter).
In this standard, the following verbal forms are used: “shall” indicates a requirement; “should” indicates arecommendation; “may” indicates a permission; “can” indicates a possibility or a capability. Further details
can be found in the ISO/IEC Directives, Part 2.

2.

Normative references

The following referenced documents are indispensable for the application of this standard. For both dated
and undated references, the latest edition of the referenced document (including any amendment) applies.
PEFC ST 2002, Chain of Custody of Forest and tree-based products – Requirements(available from www.pefc.org)
Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making
available on the Union market and the export from the Union of certain commodities and products associatedwith deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (from now onwards:
EUDR).

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3.

Terms and definitions

The following terms and definitions are taken directly from the EUDR. In cases where a definition from thismodule standard differs from a definition in PEFC ST 2002, Chain of Custody of Forest and tree-based
products, the definition from this module standard prevails for the purpose of its implementation.
When used within the standard, the definitions below and any definitions from PEFC ST 2002, Chain of
Custody of Forest and tree-based products appear in bold.

3.1

Agricultural plantation

Land with tree stands in agricultural production systems, such as fruit tree plantations, oil palm plantations,olive orchards and agroforestry systems where crops are grown under tree cover; it includes all plantationsof relevant commodities other than wood; agricultural plantations are excluded from the definition of forest.
(Source: EUDR 2.6)

3.2

Agricultural use

The use of land for the purpose of agriculture, including for agricultural plantations and set-a-side
agricultural areas, and for rearing livestock.
(Source: EUDR 2.5)

3.3

Authorised representative

Any natural or legal person established in the European Union who has received a written mandate from an
operator or from a trader to act on its behalf in relation to specified tasks with regard to the operator’s or the
trader’s obligations under the EUDR.
(Source: EUDR 2.22)

3.4

Competent authority

The authorities designated by the European Member States, who are responsible for fulfilling the obligations
arising from the EUDR.
(Source: EUDR 2.32)

3.5Country of production

Country or territory where the relevant commodity used in the production of, or contained in, a relevant
product was produced.
Note: See also definition 3.36 for produced. Country of production refers to the country where the relevant
product was harvested.
(Source: EUDR 2.24)

3.6

Country risk level

Risk level assigned to each country by the European Commission, as high risk, low risk and standard riskthat the relevant product’s production does not comply with Article 3, point (a) of the EUDR.
Note 1: Article 3, point (a) of the EUDR referred to deforestation-free.
Note 2: For wood based relevant products, the risk assignment by the European Commission will coverboth deforestation and forest degradation.
Note 3: For non-wood based relevant products (such as natural rubber), the risk assignment by theEuropean Commission will only cover deforestation.

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8Note 4: In some cases, the risk assignment by the European Commission may refer to specific parts of acountry and not to the whole country.
(Source: EUDR 2.29)

3.7

Deforestation

The conversion of forest to agricultural use, whether human-induced or not. (Source: EUDR 2.3)

3.8

Deforestation-freea) the relevant products contain, have been fed with, or have been made using, relevant
commodities that were produced on land that has not been subject to deforestation after 31
December 2020; andb) in the case of relevant products that contain or have been made using wood, that the wood has
been harvested from the forest without inducing forest degradation after 31 December 2020.
(Source: EUDR 2.13)

Note 1: For the wood based relevant products, deforestation-free means the relevant products were
produced on land that has not been subjected to deforestation and/or inducing forest degradation after
31 December 2020.
Note 2: For non-wood based relevant products (such as natural rubber), deforestation-free means therelevant products were produced on land that has not been subjected to deforestation after 31 December
2020.

3.9

Due diligence statement

A document submitted to the EU Information System that an organisation defined as an operator and/or
non-SME trader shall make available to competent authorities, assuming its responsibility for thecompliance of the relevant product with the EUDR.
Note: The information to be included in the due diligence statement is found at the Annex 2 of the EUDR, orAppendix 1 of this standard.

3.10

EU Information System

The information system, which will be established and maintained by the European Commission, where anorganisation will have to submit their due diligence statements. This information system may also include
other functionalities defined by the European Commission.
(Source: EUDR 33)

3.11

EUDR substantiated concern

A duly reasoned claim based on objective and verifiable information regarding non-compliance with the
EUDR and which could require the intervention of competent authorities.
Note 1: EUDR substantiated concerns can be concerns by third parties (either natural or legal persons), as
well as concerns of the organisation itself.
(Source: based on EUDR 31.1)

Note 2: EUDR substantiated concerns can be raised against the relevant products or against theorganisation itself.
Note 3: EUDR substantiated concerns can be raised for relevant products that are not yet placed on theUnion market, but are produced to be placed or made available on the Union market or to be exported
from the Union market; or those relevant products that already placed or made available on or exported
from the Union market.
(Source: based on EUDR 2.31)

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3.12

ForestLand spanning more than 0.5 hectares with trees higher than 5 metres and a canopy cover of more than
10 %, or trees able to reach those thresholds in situ, excluding land that is predominantly under agriculturalor urban land use.
(Source: EUDR 2.4)

3.13

Forest degradation

Structural changes to forest cover, taking the form of the conversion of:a) primary forests or naturally regenerating forests into plantation forests or into other wooded
land; orb) primary forests into planted forests.
(Source: EUDR 2.7)

3.14

Geolocation

Geographical location of a plot of land described by means of latitude and longitude coordinatescorresponding to at least one latitude and one longitude point and using at least six decimal digits. For plotsof land of more than four hectares, this shall be provided using polygons with sufficient latitude andlongitude points to describe the perimeter of each plot of land.
(Source: EUDR 2.28)

3.15

In the course of a commercial activity

For purpose of processing, for distribution to commercial or non-commercial consumers, or use in thebusiness of the operator or trader itself.
(Source: EUDR 2.19)

3.16

Making available on the Union market

Any supply of a relevant product for distribution, consumption or use on the Union market in the courseof a commercial activity, whether in return for payment or free of charge.
(Source: EUDR 2.18)

3.17

Member States

A member country of the European Union where the EUDR is applicable.

3.18

Naturally regenerating forest

Forest predominantly composed of trees established through natural regeneration; it includes any of thefollowing:a) forests for which it is not possible to distinguish whether planted or naturally regeneratedb) forests with a mix of naturally regenerated native tree species and planted or seeded trees, andwhere the naturally regenerated trees are expected to constitute the major part of the growing
stock at stand maturityc) coppice from trees originally established through natural regenerationd) naturally regenerated trees of introduced species(Source: EUDR 2.9)

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3.19

Negligible risk

The identified level of risk following the implementation of a risk assessment, as per applicable PEFC EUDRDDS requirements, that indicates that the relevant product shows no cause for concern that it originated incontroversial sources and/or non-compliant products, and/or was mixed at the supply chain level with
relevant products of unknown origin or relevant products originating in controversial sources and/or
non-compliant products.
(Source: EUDR 2.26)

3.20

Non-compliant products

Relevant products that do not comply with Article 3 of the EUDR.
Note 1: Article 3 of the EUDR defines that relevant commodities and relevant products shall not be
placed or made available on the Union market or exported, unless all the following conditions are fulfilled:a) they are deforestation-freeb) they have been produced in accordance with the relevant legislation of the country of
production; andc) they are covered by a due diligence statement
Note 2: c) of article 3 of the EUDR is applicable only for relevant products placed or made available on
the Union market or exported from the Union market by an operator or a trader.
(Sources: EUDR 3, EUDR 2.15)

3.21

Non PEFC-EUDR

The material category covering relevant products, delivered with or without a reference number, thathave not gone through the PEFC EUDR DDS.

3.22

Non-SMEAn enterprise that is not classified as an SME (micro, small and medium-sized enterprise). See definition
3.42.
Note: The definition is applicable for an organisation established in the Member States.

3.23

Operator

Any natural or legal person who, in the course of a commercial activity, places relevant products on theUnion market or exports them from the Union market.
Note 1: SME and non-SME operators are subject to different requirements.
Note 2: An organisation may act as an operator or a trader at the same time, depending on their position in
the supply chain.
(Source: EUDR 2.15)

3.24

Organisation

Person or group of people that has its own functions with responsibilities, authorities, and relationships toachieve its objectives.
Note 1: In the context of this standard, an organisation implements the requirements of this standard while
holding or applying to hold a PEFC recognised certificate that includes the PEFC EUDR DDS under its
scope.

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11Note 2: In context of EUDR for operator and trader: ‘Person’ means a natural person, a legal person or any
association of persons that is not a legal person, but which is recognised under the European Union or
national law as having the capacity to perform legal acts; “group of people” means a group of “persons”.
(Source: EUDR 2.20, 2.21)

3.25

Other wooded land

Land not classified as forest spanning more than 0.5 hectares, with trees higher than 5 metres and a canopy
cover of 5 to 10 %, or trees able to reach those thresholds in situ, or with a combined cover of shrubs,
bushes and trees above 10 %, excluding land that is predominantly under agricultural or urban land use.
(Source: EUDR 2.12)

3.26

PEFC-EUDR claim

An organisation’s declaration on a relevant product that has gone through the PEFC EUDR DDS andresulted in no or negligible risk, stated in sales and delivery documentation, namely, ‘PEFC-EUDR’. This
claim prefix shall always be used together with a PEFC ST 2002 PEFC claim (as per definition 3.27, PEFC
ST 2002, namely the claims “X% PEFC certified” and “PEFC controlled sources”).
Example: PEFC-EUDR 100% PEFC Origin, PEFC-EUDR X% PEFC certified or PEFC-EUDR PEFC
controlled sources.
Note: The PEFC-EUDR claim always applies to 100% of the relevant product to which the claim refers,
independently of the percentage of PEFC certified material included in the relevant product.

3.27

PEFC EUDR DDS material categories

Material with certain characteristics, namely PEFC-EUDR referenced, PEFC-EUDR non-referenced and
Non PEFC-EUDR.
Note: The organisation shall conduct both the material classification as per PEFC ST 2002, and this PEFC
EUDR DDS module standard.

3.28

PEFC EUDR Due Diligence System (PEFC EUDR DDS)

A framework of procedures and measures, namely collection of information, risk assessment and risk
mitigation, implemented by an organisation to reduce the risk that relevant products originate from, or are
mixed at supply chain level with, controversial sources and/or non-compliant products. In addition, thePEFC EUDR DDS also includes requirements on substantiated concerns and EUDR substantiatedconcerns, due diligence statement submission, no placement on the market, reporting to the competentauthorities and responsibility not to place the relevant product on, or export it from, the Union market that
may come from controversial sources and/or non-compliant products.
Note: The responsibility of compliance with the EUDR or any other legal obligations rests fully and solely
with the organisation defined as the operator and/or trader.

3.29

PEFC-EUDR non-referenced

The material category covering relevant products delivered with a PEFC-EUDR claim, by a supplier
covered by a PEFC recognised certificate that includes the PEFC EUDR DDS in its scope, that has not yet
been placed on the Union market and therefore is not accompanied by a reference number.

3.30

PEFC-EUDR referenced

The material category covering relevant products delivered with a PEFC-EUDR claim and a reference
number by a supplier covered by a PEFC recognised certificate that includes the PEFC EUDR DDS in its
scope.

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3.31

Place on the Union market

When a relevant commodity or relevant product is first made available on the Union market.
(Source: EUDR 2.16)

3.32

Plantation forest

A planted forest that is intensively managed and meets, at planting and stand maturity, all the following
criteria: one or two species, even age class, and regular spacing; it includes short rotation plantations forwood, fibre and energy, and excludes forests planted for protection or ecosystem restoration, as well as
forests established through planting or seeding, which at stand maturity resemble or will resemble naturally
regenerating forests.
(Source: EUDR 2.11)

3.33

Planted forest

Forest predominantly composed of trees established through planting and/or deliberate seeding, provided
that the planted or seeded trees are expected to constitute more than 50% of the growing stock at maturity; it
includes coppice from trees that were originally planted or seeded.
(Source: EUDR 2.10)

3.34

Plot of land

Land within a single real-estate property, as recognised by the law of the country of production, whichenjoys sufficiently homogeneous conditions to allow an evaluation of the aggregate level of risk of
deforestation and forest degradation associated with relevant commodities produced on that land.
(Source: EUDR 2.27)

3.35

Primary forest

Naturally regenerated forest of native tree species, where there are no clearly visible indications of humanactivities, and the ecological processes are not significantly disturbed.
(Source: EUDR 2.8)

3.36

Produced

Grown, harvested, obtained from or raised on relevant plots of land or as regards cattle, on establishments.
(Source: EUDR 2.14)

3.37

Reference number

The reference number that an operator or a non-SME trader obtains from the EU Information Systemafter submitting a due diligence statement.
Note 1: Reference number is known as reference number of due diligence statement.
Note 2: Only an organisation defined as an operator and/or trader, who directly places relevant productson the Union market or export it from the Union market, can obtain the reference number.

3.38

Relevant commodities

Cattle, cocoa, coffee, oil palm, rubber, soya and wood.
Note: The list of relevant commodities is subject to revision by the European Commission.
(Source: EUDR 2.1)

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3.39

Relevant legislation of the country of production

The laws applicable in the country of production concerning the legal status of the area of production interms of:a) land use rightsb) environmental protectionc) forest-related rules, including forest management and biodiversity conservation, where directly
related to wood harvestingd) third parties’ rightse) labour rightsf)human rights protected under international lawg) the principle of free, prior and informed consent (FPIC), including as set out in the UN Declarationon the Rights of Indigenous Peoplesh) tax, anti-corruption, trade and customs regulations(Source: EUDR 2.40)

3.40

Relevant productProducts listed in Annex I of the EUDR that contain, have been fed with, or have been made using relevant
commodities.
Note 1: Annex 1 of the EUDR is subject to periodical revision by the European Commission.
Note 2: Annex 1 refers to the relevant products based on their Harmonised System Codes (HS-Codes). See
Annex 1 of the EUDR for further information.
Note 3: The scope of this standard is limited to relevant products made with forest and tree based material
and forest and tree based products.
(Source: EUDR 2.2)

3.41

Significant risk

The identified level of risk following the implementation of a risk assessment, as per applicable PEFC EUDR
DDS’s requirements, that indicates that the relevant product shows cause for concern that it originated incontroversial sources and/or non-compliant products, and/or was mixed at the supply chain level with
relevant products of unknown origin or relevant products originating in controversial sources and/or
non-compliant products.
(Source: based on EUDR 2.26)

3.42

SME

‘Micro, small and medium-sized enterprise’ or ‘SME’ means micro, small and medium-sized undertakings as
defined in Article 3 of Directive 2013/34/EU of the European Parliament and of the Council.
Note: The definition is applicable for an organisation established in the Member States.
(Source: EUDR 2.30)

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3.43

TraderAny organisation in the supply chain other than the operator who, in the course of a commercial activity,
makes relevant products available on the Union market.
Note 1: SME and non-SME traders are subject to different requirements.
Note 2: An organisation may act as an operator and/or a trader at the same time, depending on theirposition in the supply chain.
(Source: EUDR 2.17)

3.44

Union market

The market of the European Union where any relevant product is placed on or made available or exported
from.

3.45

Waste

Any substance or object which the holder discards or intends or is required to discard.
(Source: Article 3, point (1), of Directive 2008/98/EC)

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4.

PEFC EUDR Due Diligence System (DDS) requirements

4.1

General

4.1.1

The organisation shall operate a PEFC EUDR DDS to minimise the risk that the relevant
products it procures originate in, and/or are mixed at the supply chain level with, controversial
sources and/or non-compliant products.

4.1.2

The organisation shall define the DDS that it wants to implement at the product group level, either
the PEFC EUDR DDS or the PEFC ST 2002 DDS.

4.1.3

The organisation shall make sure that any relevant product entering as an input for a PEFC
product group for which the PEFC EUDR DDS is applied, goes through this PEFC EUDR DDS
and results in no or negligible risk before implementing the PEFC chain of custody method.
(Source: based on EUDR 4.1)

4.1.4

The organisation shall implement the PEFC EUDR DDS in three steps relating to:a) collection of information (chapter 5)b) risk assessment (chapter 6)c) risk mitigation (chapter 8), when applicable(Source: EUDR 8.2)

4.1.5

In addition, the organisation shall complete the following steps:a) substantiated concerns (chapter 7)b) submission of a due diligence statement to the EU Information System, where applicable(section 9.1)c) publicly report on their Due Diligence System on an annual basis, for organisations defined as
non-SME operators and/or non-SME traders (section 9.2)d) no placement on the market (chapter 10)

4.1.6

The organisation shall provide required information as per 4.4 and chapter 5 to their PEFC
customers.
(Source: based on EUDR 4.7)

4.1.7

The organisation shall review its PEFC EUDR DDS at least annually, and whenever theorganisation becomes aware of new developments or changes in the information that could
influence the DDS and revise the DDS to take account to those developments, if needed.
(Source: EUDR 12.2)

4.1.8

An organisation defined as an operator and/or trader shall offer any necessary assistance to thecompetent authorities to conduct their obligations under the EUDR, including providing access tothe premises and making available all documentation and records related to its PEFC EUDR DDS.
(Source: EUDR 4.6)

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4.2

Additional management system requirements

4.2.1

The organisation shall establish written procedures to exercise a PEFC EUDR DDS under theirchain of custody management system. These procedures shall be kept up to date.
(Source: EUDR 12.1)

4.2.2

An organisation defined as a non-SME operator and/or non-SME trader shall appoint a staff
member as the EUDR compliance officer.
(Source: EUDR 11.2a)

Note: The EUDR compliance officer can be the same person responsible for the organisation’s PEFC chainof custody certification (PEFC ST 2002, 4.3.1.2).
4.2.3

The organisation shall keep all documentation related to its PEFC EUDR DDS for at least five
years. Documentation includes all records, measures, and procedures, as set out in chapters 5, 6,
and 8.
(Source: EUDR 12.2 and 12.5)

4.3

Additional requirements for the identification of input material

4.3.1

For each relevant product used as an input for a PEFC product group for which the PEFC
EUDR DDS is applied, in addition to the documentation indicated in PEFC ST 2002, 5.1.1, theorganisation shall obtain:a) Information from the supplier to identify the quantity of the relevant product, as follows:i. For a relevant product entering or leaving the Union market, the quantity is to be expressed in
kilograms of net mass and, where applicable, in the supplementary unit set out in Annex I to
Council Regulation (EEC) No 2658/87 (20) against the indicated Harmonised System code.
ii. In all other cases, the quantity is to be expressed in net mass or, where applicable, volume ornumber of items; a supplementary unit is applicable where it is defined consistently for all
possible subheadings under the Harmonised System code referred to in the due diligencestatement.
b) In addition to the applicable PEFC chain of custody claims, the PEFC-EUDR claim specifically foreach claimed product, andc) Any additional information as needed to conduct the PEFC EUDR DDS.
(Source: EUDR 9.1b)

4.3.2

For relevant products delivered with a PEFC-EUDR claim, the organisation shall verify on the
PEFC website that the supplier holds a PEFC recognised certificate that includes the PEFC
EUDR DDS under its scope. In addition, the organisation shall verify that the relevant product iscovered by the scope of the PEFC EUDR DDS.

4.3.3

For each relevant product used as an input for a PEFC product group for which the PEFC EUDRDDS is applied, before implementing the PEFC EUDR DDS, the organisation shall, in addition toclassifying it according to the material categories as per PEFC ST 2002, also classify it according
to the PEFC EUDR DDS material categories. The PEFC EUDR DDS material categories are:a) PEFC-EUDR referencedb) PEFC-EUDR non-referencedc) Non PEFC-EUDRPEFC ST 2002-1:2024 - Requirements for the Implementation of PEFC EUDR Due Diligence System

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4.4

Additional requirements for the declaration of outputs

4.4.1

For outputs from a PEFC product group for which the organisation makes a PEFC-EUDR claim
to a PEFC customer, it shall provide the customer with documentation on:a) Quantity of the relevant product, as follows:i. For relevant products entering or leaving the Union market, the quantity is to be expressed in
kilograms of net mass and, where applicable, in the supplementary unit set out in Annex I to
Council Regulation (EEC) No 2658/87 (20) against the indicated Harmonised System code.
ii. In all other cases, the quantity is to be expressed in net mass or, where applicable, volume ornumber of items; a supplementary unit is applicable where it is defined consistently for all
possible subheadings under the Harmonised System code referred to in the due diligencestatement.
b) The PEFC-EUDR claim specifically for each claimed product, in addition to the applicable PEFC
chain of custody claims, and;c) Additional information as needed for the PEFC customer to conduct the PEFC EUDR DDS.
(Source: EUDR 9.1b)

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5.

Collection of information

5.1

General

5.1.1

For a relevant product delivered with a PEFC-EUDR claim to be classified as PEFC-EUDR
referenced, the organisation shall obtain from its supplier and keep records of:a) the reference numberb) on request, any information as per 5.1.2 or any other information that the organisation may needto confirm that the relevant product has no or negligible risk. If the supplier does not possess
the requested information, the request shall be passed on to its supplier(s).

5.1.2

For a relevant product delivered with a PEFC-EUDR claim to be classified as PEFC-EUDR nonreferenced, the organisation shall obtain from its supplier, as appropriate, and keep records of:a) a description, including the trade name and type of the relevant products as well as, in the case of
relevant products that contain or have been made using wood, the common name of the species
and their full scientific name. The product description shall include the list of relevant
commodities or relevant products contained therein or used to make those products.
(Source: EUDR 9.1a)b) the country of production of the relevant product and where applicable, parts thereof
Note: In the context of this standard, the country of production means the country of harvesting.
(Source: EUDR 9.1c), EUDR 2.14)c) the geolocation of all the plots of land where the relevant products were produced.
(Source: EUDR 9.1d)d) the date or time range of production
Note: In the context of this standard, production means harvest.
(Source: EUDR 9.1d and EUDR 2.14)e) the name, postal address, and email address of any business or person from whom they havebeen supplied with the relevant products(Source: EUDR 9.1e)f)

the name, postal address and email address of any business, operator or trader to whom therelevant products have been supplied(Source: EUDR 9.1f)g) adequately conclusive and verifiable information that the relevant products are deforestationfree(Source: EUDR 9.1g)h) adequately conclusive and verifiable information that the relevant commodities have been
produced in accordance with the relevant legislation of the country of production, including
any arrangement conferring the rights to use the respective area for the purposes of the productionof the relevant commodity
Example 1: Information sources that can be used include a valid FLEGT licence.
Example 2: For relevant products originating in countries the European Commission has assigned a low
country risk level, an example of conclusive and verifiable information can be a harvesting permit or
harvesting declaration.
(Source: EUDR 9.1h)

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5.1.3For a relevant product classified as non PEFC-EUDR, the organisation shall obtain all theinformation required under 5.1.2. If the supplier cannot provide this information, the relevant
product shall be directly considered as having significant risk and the organisation shall mitigate
the risk as per chapter 8. The relevant product shall not enter the PEFC chain of custody method
step, and neither be placed, or made available on or exported from, the Union market until the riskhas been mitigated.

5.1.4

An organisation defined as an operator and/or non-SME trader shall make available to thecompetent authorities upon request the information, documents and data collected under 5.1.2,
4.3.1.a, and 4.4.1 a.
(Source: EUDR 9.2)

5.1.5

An organisation defined as an operator and/or non-SME trader shall keep all collected
information, documents and data relating to each relevant product for five years from the date of
the placing, or of the making available, on the Union market or of the export of the relevant
product.
(Source: EUDR 9.1)

Table 2: Overview of the information required to classify the relevant product according to the PEFC EUDR
material categories

Material category
Information collection requirements

PEFC-EUDR
referenced

PEFC-EUDR
non-referenced

Information as per 5.1.2 to be obtained

X

Information as per 5.1.2 to be obtained,
on request

X

Reference number

X

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Non PEFC-EUDR
X

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6.

Risk assessment

6.1

General

6.1.1

The organisation shall verify and analyse the information collected in accordance with chapter 4
and chapter 5, and any other relevant documentation. Based on that information anddocumentation, the organisation shall carry out a risk assessment for each relevant productused as an input for a PEFC product group for which the PEFC EUDR DDS is applied, except for
any relevant products that comply with PEFC’s definition of recycled material.
(Source: EUDR 10.1)

6.1.2

The risk assessment shall establish whether there is a risk that the relevant product input
intended to be placed on, or exported from, the Union market originated from controversial
sources (PEFC ST 2002, 3.7) and/or non-compliant products (definition 3.20).

6.1.3

The organisation shall not implement the PEFC chain of custody method and shall not place therelevant product on, or export it from, the Union market unless the risk assessment concludes
the relevant product has no or negligible risk.
(Source: EUDR 10.1)

6.1.4

The organisation shall consider the following risks when conducting the risk assessment:a) The relevant product is sourced from activities where deforestation and/or forest degradation
occurred after 31 December 2020 (section 6.2).
b) The relevant product was not produced in compliance with relevant legislation of the countryof production (section 6.3).
c) The relevant product originated from activities where the capability of the forest to produce a
range of wood and non-wood forest products and services on a sustainable basis is not maintainedor harvesting levels exceed a rate that can be sustained in the long term, or genetically modified
trees occurred (section 6.4).

Note: c) corresponds to the elements (b) and (i) of the definition of controversial sources in PEFC ST
2002, 3.7, which are not covered by EUDR. To make sure that PEFC EUDR-claimed material addresses
completely PEFC’s definition and approach for controversial sources, organisations implementing thePEFC EUDR DDS also need to address the parts where PEFC’s controversial sources go beyond EUDR.
d) Supply chain level and risk of mixing (section 6.5).
6.1.5

The organisation’s risk assessment shall result in the classification of the relevant product input
into no or negligible risk or significant risk categories.

6.1.6

The organisation shall ensure that there is no substantiated concern and/or EUDR
substantiated concern, or that any substantiated concern and/or EUDR substantiatedconcern is resolved, before classifying the relevant product as having no or negligible risk.
(Source: EUDR 10.2e)

6.1.7

If the organisation classifies the relevant product as having significant risk for one or several of
those aspects of the risk assessment as described in 6.2, 6.3, 6.4 and 6.5, the organisation shallmanage the identified risk(s) according to chapter 8.
(Source: based on EUDR 11.1)

6.1.8

When sourcing relevant products from suppliers defined as operators and/or non-SME traders,the organisation shall check whether the relevant product is delivered with a reference number.
If not, the relevant product shall be considered as having significant risk.
(Source: EUDR 3.c)

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6.1.9When conducting the risk assessment, the organisation shall take into account:a) The conclusion of the meetings of the European Commission expert groups supporting theimplementation of the EUDR, as published in the European Commission’s expert group register.
(Source: EUDR 10.2k)b) The sources, reliability, validity, and links to other available documentation referred to in 4.3 and5.1.2, and any information that would point to a risk that the relevant products do not comply with
EUDR.
(Source: EUDR 10.2g)

6.1.10The organisation shall document and keep records of the risk assessment process, including
information and evidence obtained and used to justify the degree of risk against the risk
assessment criteria set out in 6.2, 6.3, 6.4 and 6.5.
(Source: EUDR 10.1)

6.1.11

The risk assessment shall be documented, reviewed at least annually, and revised as needed. The
risk assessment shall also be reviewed when changes regarding the information listed inrequirements 4.3 and 5.1.2 occur, or when there are new developments affecting the organisation’s
PEFC EUDR DDS, and revised as needed.
(Source: EUDR 10. 4)

6.1.12An organisation defined as an operator and/or non-SME trader shall be able to demonstrate how
the information gathered was checked against the risk assessment criteria set out in 6.2, 6.3, 6.4
and 6.5 and how it determined the degree of risk.
(Source: EUDR 10. 4)

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6.2

Assessment of the risk that relevant products are sourced from activities where
deforestation and/or forest degradation occurred after 31 December 2020

6.2.1

The organisation may classify relevant products as having no or negligible risk of originatingfrom areas where deforestation and/or forest degradation occurred after 31 December 2020,
if any one of the indicators in Table 3 applies.
(Source: based on EUDR 10.2)

Table 3: List of indicators of no or negligible risk that relevant products are produced from areas where
deforestation and/or forest degradation occurred after 31 December 2020

i. The relevant product was delivered with a PEFC-EUDR claim and additional information as per
chapter 5, by a supplier that holds a PEFC recognised certificate with this PEFC EUDR DDS under
its scope, and has implemented the PEFC EUDR DDS for the specific relevant product.
Example: PEFC-EUDR X% PEFC certified
ii. The relevant product originates from a country of production, or parts thereof, where there is noprevalence of deforestation or forest degradation and for which the European Commission assigns acountry risk level that is low.
(Source: EUDR 13.1)

iii. The relevant product was delivered with a valid 100% PEFC certified claim, from a PEFC SFM
certificate holder certified against a PEFC endorsed standard that is adapted to EUDR.
Note: As PEFC endorsed standards become adapted to EUDR, they will be available on the PEFC
website.
iv. The relevant product was declared as fully certified against an EUDR adapted forest certification
scheme (other than a PEFC endorsed standard) supported by a valid certificate issued by a third-party
certification body and delivered with a reference number. The organisation shall prove the adaption
to EUDR of the forest certification scheme.
v. A relevant product for which the organisation has:a) obtained the geolocation of the plots of land, and the date or time range of production, where therelevant product was produced, andb) verified this information to demonstrate that the relevant product does not originate in an area
where deforestation and/or forest degradation occurred after 31 December 2020, andc) recorded the evidence

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6.3

Assessment of the risk that relevant products are sourced from activities notcomplying with relevant legislation of the country of production

6.3.1

The organisation may classify relevant products as having no or negligible risk of originatingfrom activities not complying with relevant legislation of the country of production, if any one of
the indicators in Table 4 applies.
(Source: based on EUDR 10.2)

Table 4: Indicators of no or negligible risk of not complying with relevant legislation of the country of production

i. The relevant product was delivered with a PEFC-EUDR claim and additional information as per
chapter 5, by a supplier that holds a PEFC recognised certificate with this PEFC EUDR DDS under
its scope, and has implemented the PEFC EUDR DDS for the specific relevant product.
Example: PEFC-EUDR X% PEFC certified
ii. The relevant product originates from a country of production, or parts thereof, where there is noprevalence of deforestation or forest degradation and for which the European Commission assigns acountry risk level that is low(Source: EUDR 13. 1)

iii. The relevant product was delivered with a valid 100% PEFC certified claim, from a PEFC SFM
certificate holder certified against a PEFC endorsed standard that is adapted to EUDR.
Note: As PEFC endorsed standards become adapted to EUDR, they will be available on the PEFC
website.
iv. A relevant product that falls within the scope of Regulation (EC) No 2173/2005 and is covered by avalid FLEGT license from an operational licensing scheme shall be deemed to comply with Article 3,
point (b), of EUDR.
(Source: EUDR 10.3)

v. The relevant product was declared as fully certified against an EUDR adapted forest certification
scheme (other than a PEFC endorsed standard) supported by a valid certificate issued by a third-party
certification body and delivered with a reference number. The organisation shall prove the adaption
to EUDR of the forest certification scheme.

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6.3.2

If none of the indicators in Table 4 apply, the organisation may classify relevant products as
having no or negligible risk of originating from activities not complying with relevant legislationof the country of production, if all the indicators in Table 5 apply.
(Source: based on EUDR 10.2)

Table 5: Supplementary indicators of no or negligible risk of not complying with relevant legislation of thecountry of production

i. The absence of concerns listed below regarding the relevant product with relation to the country of
production or parts thereof:a) Level of corruption.
b) Prevalence of document and data falsification.
c) Tree species included in the relevant product known for prevalence of activities covered by the term
controversial sources (PEFC ST 2002, 3.7(a) or (b)) in the country/region, or activities that do notcomply with EUDR.
d) Lack of:I. law enforcement
II. environmental protection
III. forest-related rules, including forest management and biodiversity conservation, where directly
related to harvesting, and/or low level of forest governance and law enforcement
Source: EUDR 2.40 (b), (c); EUDR 10.2(h)e) Violation of:I. land use rights
II. third parties’ rights
III. labour rights
Note: Organisations can consider internationally recognised labour rights obligations, such as ILO
Declaration on Fundamental Principles and Rights at Work (1998)
IV. international human rights
Source: EUDR 2.40(a), (d), (e), (f)f) Presence of:I. armed conflict or conflict timber trade
II. sanctions imposed by the UN Security Council or the Council of the European Union
III. infringements of tax, anti-corruption, trade and customs regulations
Source: EUDR 10.2 (h), 2.40(h), PEFC ST 2002, 3.7.hii. The relevant product originates from a country of production where there is no presence ofIndigenous Peoples. If there is presence of Indigenous Peoples in the country of production, or parts
thereof, the following shall apply:a) There is consultation and cooperation in good faith with Indigenous Peoples in the country of
production or parts thereof.
b) Absence of existence of duly reasoned claims by Indigenous Peoples based on objective andverifiable information regarding the use or ownership of the area used for the purpose of
producing the relevant commodity.
c) The principle of free, prior and informed consent (FPIC), including as set out in the UN
Declaration on the Rights of Indigenous Peoples.
Note: c) is to be understood in the context of relevant laws applicable in the country of production
concerning the legal status of the area of production.
Source: EUDR 10.2 (c), (d), (e)PEFC ST 2002-1:2024 - Requirements for the Implementation of PEFC EUDR Due Diligence System

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6.4

Assessment of the risk that relevant products are sourced from activities where thecapability of the forest to produce a range of wood and non-wood forest products
and services on a sustainable basis is not maintained or harvesting levels exceed arate that can be sustained in the long term, or genetically modified trees occurred.

6.4.1

The organisation may classify relevant products delivered with a PEFC chain of custody claim
from a supplier that holds a PEFC recognised certificate as having no or negligible risk oforiginating from activities where the capability of the forest to produce a range of wood and nonwood forest products and services on a sustainable basis is not maintained or harvesting levels
exceed a rate that can be sustained in the long term, or that genetically modified trees occurred.

6.4.2

For relevant products that are not delivered with a PEFC chain of custody claim from a supplierthat holds a PEFC recognised certificate, the organisation may classify the relevant product ashaving no or negligible risk of originating from activities where the capability of the forest to
produce a range of wood and non-wood forest products and services on a sustainable basis is not
maintained or harvesting levels exceed a rate that can be sustained in the long term, or thatgenetically modified trees occurred, if all indicators in Table 6 apply.

Table 6: Indicators for no or negligible risk that relevant products are sourced from activities where thecapability of the forest to produce products and services on a sustainable basis is not maintained or harvestinglevels exceed a rate that can be sustained, or genetically modified trees occurredi. Activities where the capability of the forest to produce a range of wood and non-wood forest products
and services on a sustainable basis is maintained or harvesting levels do not exceed a rate that can besustained in the long term.
Example: Data source where this can be checked: FAO Forest Resource Assessment, STIX, UNECE,
European Environment Agency, or Forest Trends
ii. According to publicly available data, genetically modified forest and tree based organisms are notproduced in the country/region and are not placed on the market.
Note: These indicators are corresponding to the elements (b), and (i) of the definition of controversial
sources, PEFC ST 2002, 3.7.

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6.5

Assessment of the risk that relevant products are mixed with controversial sources
and/or non-compliant products at supply chain level

6.5.1

The organisation may classify relevant products as having no or negligible risk of being mixed
with material originating from controversial sources and/or non-compliant products at supply
chain level if none of the indicators in Table 7 apply.
(Source: Based on EUDR 10. 2)

Table 7: List of indicators for significant risk at the supply chain leveli. Risk of circumvention of the EUDR or risk of being mixed with relevant products of unknown origin or
material originating in controversial sources and/or non-compliant products.
(Source: EUDR 10.2(j), PEFC ST 2002)

ii. Complexity of the relevant supply chain.
(Source: EUDR 10.2(i))

iii. Stage of processing of the relevant product, in particular, difficulties in connecting the relevant productto the plot of land where the relevant products were produced.
(Source: EUDR 10.2(i))

iv. Information on the history of non-compliance with illegal sources as per PEFC’s definition forcontroversial sources (PEFC ST 2002, 3.7.a), with EUDR or with related legislation, by organisations
along the relevant supply chain.
(Source: EUDR, 10.2(l))

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7.
7.1

Substantiated concerns
If the organisation obtains or is made aware of relevant information, including as a result of therisk assessment (chapter 6) and including EUDR substantiated concerns submitted under Article
31 of the EUDR, that would point to a risk that the relevant product originates in controversial
sources (substantiated concerns), does not comply with the EUDR, or that the EUDR iscircumvented (EUDR substantiated concerns), the organisation shall address them as per
chapter 6 and chapter 8.
(Source: EUDR 13.2)

7.2

For EUDR substantiated concerns, if an organisation defined as an operator and/or non-SME
trader obtains or is made aware of relevant information that would point to a risk that the relevant
product does not comply with the EUDR, or that the EUDR is circumvented, the organisation
shall immediately communicate any relevant information to the competent authority.
(Source: EUDR 13.2)

7.3

The organisation shall ensure that substantiated concerns and EUDR substantiated concerns
are investigated promptly, starting no later than ten workdays from the identification of theconcerns.

7.4

If an organisation defined as an operator and/or non-SME trader obtains or is made aware of
relevant new information, including EUDR substantiated concerns, indicating that a relevant
product that it placed or made available on the Union market is at risk of not complying with the
EUDR, the organisation shall immediately inform the competent authorities of the Member
States in which it placed or made available the relevant product on the Union market, as wellas the traders to whom it supplied the relevant product. In the case of exports, the operator shallinform the competent authority of the Member State that is the country of production.
(Source: EUDR 4.5)

7.5

If an organisation defined as an SME trader obtains or is made aware of relevant new
information, including EUDR substantiated concerns, indicating that a relevant product that it
made available on the Union market is at risk of not complying with the EUDR, the organisation
shall immediately inform the competent authorities of the Member States in which the relevant
product was made available on the Union market, as well as the traders to whom it supplied therelevant product.
(Source: EUDR 5.5)

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8.

Risk mitigation

8.1

General

8.1.1

Except where a risk assessment carried out in accordance with chapter 6 reveals that there is no or
negligible risk that the relevant products are non-compliant products, the organisation shall,prior to implementing the PEFC chain of custody method, adopt risk mitigation procedures andmeasures that are adequate to achieve no or negligible risk.
(Source: EUDR 11.1)

8.1.2

The procedures or measures may include any of the following:a) requiring additional information, data, or documents (Source: EUDR 11.1(a))b) carrying out independent surveys or audits (Source: EUDR 11.1(b))c) other measures pertaining to information requirements set out in chapter 5 (Source: EUDR, 11.1.(c))

8.1.3

Such procedures and measures may also include supporting the organisation’s suppliers toachieve compliance with the EUDR, in particular smallholders, through capacity building andinvestments.
(Source: EUDR 11.1)

8.1.4

The organisation shall have in place adequate and proportionate policies, controls andprocedures to mitigate and manage effectively the risks identified. Those policies, controls andprocedures shall include:a) Model risk management practices, reporting, record-keeping, internal control and compliancemanagement, including the appointment of a compliance officer at management level for an
organisation defined as a non-SME operator and/or non-SME trader (see also 4.2.2).
b) An independent audit function to check the internal policies, controls and procedures referred to in
8.1.4.a) for an organisation defined as a non-SME operator and/or non-SME trader.
(Source: EUDR 11.2)

8.1.5

The organisation’s decisions on risk mitigation procedures and measures shall be documented andreviewed at least on an annual basis.
(Source: EUDR 11.3)

8.1.6

An organisation defined as an operator and/or non-SME trader shall make available its decisionon its risk mitigation procedures and measures to the competent authorities upon request.
(Source: EUDR 11.3)

8.1.7

An organisation defined as an operator and/or non-SME trader shall be able to demonstrate how
the decisions on its risk mitigation procedures and measures were taken.
(Source EUDR 11.3)

8.2

Requiring additional information, data and documents

8.2.1

The organisation shall request from all suppliers delivering supplies with significant risk, to:a) Provide the organisation with all the detailed information in 4.3 and 5.1.2, and any additional data
and documents on the whole supply chain and production area of the supply’s origin.
b) Enable the organisation to carry out a second party or a third-party audit of the supplier’s
operations as well as operations of the previous suppliers in the chain.

Note: These procedures can be ensured by contractual agreements or a written self-declaration by the
supplier.
8.2.2

The information submitted by the supplier shall allow the organisation to plan and execute audits.

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8.3

Audits8.3.1

The organisation’s risk mitigation procedures and measures shall include audits of suppliersdelivering supplies with significant risk when the documentation provided and reviewed does notprovide enough confidence that the relevant product does not origin from controversial sources
and/or non-compliant products. The audits can be carried out by the organisation itself (second
party audit) or by a third party on behalf of the organisation.

8.3.2

The organisation shall demonstrate that personnel carrying out audits have sufficient knowledge
and competence in the EUDR, PEFC EUDR DDS, local business, cultural and social customs, andapplicable treaties, conventions legislation, governance and law enforcement, relevant to the origin
of supplies with significant risk and to the risk(s) identified.

8.3.3

The organisation shall determine a sample of supplies with significant risk delivered by the
supplier to be verified. The size of the annual sample shall be at least the square root of thenumber of supplies with significant risk per one year: (y=√x), rounded up to the nearest whole
number. Where the previous audits proved to be effective in fulfilling the objective of this document,
the size of the sample may be reduced to y=0.8 √x, rounded up to the next whole number.

8.4

Corrective measures

8.4.1

As part of the policies, controls and procedures to manage effectively the risks identified, theorganisation shall include procedures for implementing corrective measures for suppliersdelivering supplies with significant risk.

8.4.2

The range of corrective measures shall be based on the scale and seriousness of the risk and shallconsider cancellation or suspension of any contract or order for relevant products until the
supplier can demonstrate that appropriate risk mitigation measures have been implemented.

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9.

Due diligence statement submission and publication

9.1

Due diligence statement submission

9.1.1

An organisation defined as an operator and/or non-SME trader shall submit a due diligencestatement covering the relevant product to the competent authority of the Member States inwhich the relevant product will be placed or made available, or exported from, the Union
Market, through the EU Information System, prior to placing the relevant product on the Union
market or exporting it.
(Source: EUDR 4.2 and EUDR 5.2)

9.1.2

The organisation shall, upon request, provide to its PEFC customer, or another organisation
further down the supply chain of the relevant product, all information necessary to demonstratethat the PEFC EUDR DDS was exercised and that no or negligible risk was found, including thereference numbers of the due diligence statements associated to those products, whereappropriate.
(Source: EUDR 4.7)

9.1.3

The due diligence statement can be submitted by an organisation defined as an operator
and/or non-SME trader or its authorised representative. In any case, an organisation defined
as an operator and/or non-SME trader shall retain their responsibility for the compliance with the
EUDR.
(Source: EUDR 4.3)

9.1.4

An organisation defined as an operators and/or non-SME trader shall keep the due diligencestatement at least five years from the date it was submitted into the EU Information System.
(Source: EUDR 4.3)

9.1.5

An organisation defined as an SME trader shall keep the reference numbers associated to therelevant product at least five years from the date of the making available on the Union market
and shall provide that information to the competent authorities upon request.
(Source: EUDR 5.4)

9.1.6

The due diligence statement shall cover at least information specified in Appendix 1.

9.2

Due Diligence System report and publication

9.2.1

An organisation that is defined as a non-SME operator and/or non-SME trader, shall, on anannual basis, publicly report as widely as possible, including via the internet, on their PEFC EUDR
DDS, including the steps taken by them to fulfil their EUDR obligations.
(Source: EUDR 12.3)

9.2.2

The organisation’s PEFC EUDR DDS report shall include the following information concerning therelevant product:a) A summary of the information described in requirements 4.4.1 and 5.1.2 (a) and (b)b) The conclusions of the risk assessment carried out as per chapter 6 and risk mitigation measures
undertaken as per chapter 8, and a description of the information and evidence obtained and used
to assess the risk.
c) Where applicable, a description of the process of consultation of Indigenous peoples, local
communities and other customary tenure rights holders or of the civil society organisations that arepresent in the area of production of the relevant commodities and relevant products.
(Source: EUDR 12.4)

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9.2.3An organisation defined as an operator and/or non-SME trader that falls also within the scope ofother European Union legal acts that lay down requirements regarding value chain due diligence
may fulfil their PEFC EUDR DDS reporting obligations by including the required information laid out
in requirement 9.2.2 above, when reporting in the context of those other Union legal acts.
(Source: EUDR 12.3)

Note: Examples of other legal acts regarding value chain due diligence include Directive (EU) 2022/2464 of
the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014,
Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards corporate sustainability
reporting.

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10. No placement on the market
10.1

Relevant products from unknown sources, and/or controversial sources and/or non-compliant
products shall not be included in a PEFC product group for which this PEFC EUDR DDS is
implemented.

10.2

Non-compliant products shall not be placed or made available on the Union market or
exported.
(Source: EUDR 3)

10.3

Where it is known to the organisation that the relevant products not covered by theorganisation’s PEFC chain of custody originate from illegal sources (controversial sources
definition, PEFC ST 2002, 3.7.a) and/or have not been produced in accordance with relevant
legislation of the country of production (definition 3.39), the relevant products shall not be
placed on the market.

10.4

Where the organisation has received substantiated concerns and/or EUDR substantiatedconcerns that the relevant products not covered by the organisation’s PEFC chain of custodyoriginate in illegal sources (controversial sources definition, PEFC ST 2002, 3.7.a) and/or havenot been produced in accordance with relevant legislation of the country of production(definition 3.39), the relevant product shall not be placed on the market until the concern has
been resolved in accordance with chapter 7.

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Appendix 1 (normative), Content of the Due Diligence Statement,
as per Annex 2 of the EUDR
Information shall be contained in the due diligence statement in accordance with Article 4(2) of EUDR:
1. Operator and/or non-SME trader’s name, address and, in the event of relevant commodities andrelevant products entering or leaving the Union market, the Economic Operators Registration and
Identification (EORI) number in accordance with Article 9 of Regulation (EU) No 952/2013.
2. Harmonised System code, free-text description, including the trade name as well as, where applicable,
the full scientific name, and quantity of the relevant product that the operator and/or non-SME trader
intends to place or make available on the Union market or export. For relevant products entering or
leaving the Union market, the quantity is to be expressed in kilograms of net mass and, whereapplicable, in the supplementary unit set out in Annex I to Regulation (EEC) No 2658/87 against theindicated Harmonised System code or, in all other cases, expressed in net mass specifying apercentage estimate or deviation or, where applicable, volume or number of items. A supplementary
unit is applicable where it is defined consistently for all possible subheadings under the Harmonised
System code referred to in the due diligence statement.
3. Country of production and the geolocation of all plots of land where the relevant commodities
were produced. For relevant products that contain or have been made using cattle, and for such
relevant products that have been fed with relevant products, the geolocation shall refer to all theestablishments where the cattle were kept. Where the relevant product contains or has been madeusing relevant commodities produced in different plots of land, the geolocation of all plots of land
shall be included in accordance with Article 9(1), point (d).
4. For operators and/or non-SME trader referring to an existing due diligence statement pursuant to
Article 4(8) and (9), EUDR, the reference number of such due diligence statement.
5. The text: ‘By submitting this due diligence statement the operator and/or non-SME trader confirmsthat due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or
negligible risk was found that the relevant products do not comply with Article 3, point (a) or (b), ofthat Regulation.’.
6. Signature in the following format:
Signed for and on behalf of:
Date:
Name and function: Signature:

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