Tracing the tree: certification and the EU rule

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PEFC certifies 295,982,894 hectares of forest and FSC about 173.3 million, yet the EU Deforestation Regulation treats a certificate as complementary information only ^1,2,4. From December 30, 2026, an EU pulp importer must hold the plot coordinates of the wood and file a due diligence statement. This post sets out what that means, and which tracing tools exist today.

Published October 27, 2026 · Facts as of October 27, 2026 · 10 min read · Sources listed at the end

Facts as of October 27, 2026. This page states the facts as they stood on that date. Figures, rules and company plans may have changed since publication. We review this guide every six months and update the pages.

295,982,894 haForest area certified by PEFC, December 2025, with 13,977 chain of custody certificates ¹

173.3 million haForest area certified by FSC, as of about August 2025, with 70,273 chain of custody certificates (FSC UK) ²

5 yearsHow long due diligence documents must be kept ³

At least 4%The minimum for the maximum fine: 4% of the operator's or trader's EU turnover ⁴

The 60-second version

What is it?

Two things trace wood. Voluntary certification (FSC and PEFC) audits forests and the mills that handle the wood ^1,2. The EU Deforestation Regulation (EUDR) is a law that requires coordinates for every plot where the wood grew ⁴.

Why does it matter?

The EU rule lists certification as information that can be considered in the risk assessment, and as complementary only ⁴. An importer still files geolocation and a due diligence statement. Application starts on December 30, 2026 ⁷.

How does it work?

The importer collects plot data from suppliers, assesses risk, files a statement in the Commission's Information System and receives a reference number ^5,6. Satellite checks are in production ¹⁰. Isotope testing of wood is still being built ^13,14.

Myth or fact?

"An FSC or PEFC certificate satisfies the EU deforestation rule."

See the answer

Myth. The regulation says certification may be considered as complementary information in the risk assessment, if it meets the Article 9 requirements ^3,4. The importer still needs plot geolocation and a due diligence statement ⁴.

In this post

1. How much forest is certified, and how does that compare with the EU rule?
2. Does a certificate satisfy the EU rule?
3. What must an EU importer hold from December 30, 2026?
4. How does a due diligence statement travel from forest to buyer?
5. Which tracing tools are in use, and which are still being built?
6. What does it cost, and who faces the full process?

01How much forest is certified, and how does that compare with the EU rule?

PEFC International's statistics sheet for December 2025 shows a total certified area of 295,982,894 hectares and 13,977 chain of custody certificates ¹. Europe holds 11,224 of those certificates ¹. FSC UK's facts page shows 173,270,515 certified hectares and 70,273 chain of custody certificates, with a map dated August 2025 ².

The two figures use different dates and different sources, so compare them with care. Both schemes count hectares once for their own scheme, and some forests may carry both labels. Do not add the two totals.

A mill can show its mix. UPM's origin of wood statement for its Fray Bentos mill in Uruguay, for 2025, lists FSC certified incoming wood at 87.4% and PEFC certified at 8.4% ¹¹. The statement also lists other categories that overlap, so the shares do not add to 100%. The table sets certification beside the law.

Compare

FSC, PEFC and the EUDR side by side

Sources: PEFC International, December 2025 ¹; FSC UK, about August 2025 ²; European Commission and EUR-Lex ^3,4; FSC and PEFC self-descriptions ^17,18.

	FSC	PEFC	EUDR
What it is	Certifies forests and forest-based products against its standards 17	An alliance of national forest certification systems 18	EU law, Regulation (EU) 2023/1115 4
Size	173.3 million ha, as of about August 2025 2	295,982,894 ha, December 2025 1	Pulp and paper of HS Chapters 47 and 48, except recovered and bamboo-based products 4
Chain of custody certificates	70,273 2	13,977 1	None. Each importer files its own statement 4
Who checks	Independent third-party certification bodies 17	Independent third-party certification 18	The importer, through its due diligence system 4
Role under the EU rule	Complementary information only 4	Complementary information only 4	Requires geolocation and a statement 4
Legal status	Private certification scheme 17	Non-profit certification system 18	Law. Maximum fine of at least 4% of EU turnover 4

02Does a certificate satisfy the EU rule?

No. Article 10(2)(n) of the regulation says an operator may consider complementary information on compliance, which may include information supplied by certification schemes, provided the information meets the requirements of Article 9 ^3,4. The Commission's guidance repeats this ³.

The regulation sets three conditions for pulp and paper to enter the EU market. The product must be deforestation-free, must be produced in line with the law of the country of production, and must be covered by a due diligence statement ⁴. Deforestation-free means the wood was not harvested from land deforested or degraded after December 31, 2020 ⁴. The regulation counts the conversion of natural forest into plantation forest as degradation ⁴.

A certificate is evidence in this system. It does not remove the geolocation duty or the statement. The regulation replaces the EU Timber Regulation, and UPM's own statement says so ¹¹.

03What must an EU importer hold from December 30, 2026?

The main duties apply from December 30, 2026. Micro and small companies follow on June 30, 2027 ⁷. A pulp importer is rarely a micro or small company, so December 30, 2026 is the date that counts. The checklist below sets out what the importer holds.

The scope is the whole of Chapters 47 and 48 of the EU's Combined Nomenclature, which means every pulp and paper heading, except bamboo-based and recovered (waste and scrap) products ⁴. A later act, Delegated Regulation (EU) 2026/2102, amended Annex I and took effect on September 18, 2026 ¹⁶. We could not read its annex, so check the current Annex I before you file. See the pulp watch for the dated rules.

The fine is set by each Member State. The maximum fine for a legal person must be at least 4% of its total annual EU-wide turnover ⁴.

Checklist

Six things an EU pulp importer must hold

• A due diligence statementFiled through the Information System before the pulp is placed on the EU market or exported ⁴.
• Plot geolocationThe coordinates of every plot where the wood grew, with the date or time range of production ⁴. Format: GeoJSON, six decimals ⁶.
• Evidence of two conditionsNo deforestation after December 31, 2020, and production in line with the law of the country of origin ⁴.
• A risk assessment and mitigationRequired unless all the wood comes from low-risk countries ^4,8.
• Certificates, as extra evidenceAn FSC or PEFC certificate may be considered as complementary information ⁴.
• Records for five yearsAll due diligence documents are kept for five years from the date the product is placed on the EU market or exported ³.

04How does a due diligence statement travel from forest to buyer?

The Commission describes the Information System as a specialised online tool of the TRACES platform ⁵. An operator draws plots on a map, or sends statements in bulk through a machine-to-machine connection ⁵. The system gives each statement a reference number and a verification number ⁶.

The technical rules are exact. Geolocation is sent as GeoJSON, with latitude and longitude to at least six decimal digits. Plots above 4 hectares need a polygon ⁶. A plot below that size needs one point, the European Forest Institute says ¹⁰. The European Forest Institute lists common data errors: a village center used as a proxy location, wrong coordinate formats and GPS outliers ¹⁰.

The Commission's API document, dated May 29, 2026, warned that the V3 endpoints were not yet accessible and would open once the system goes online ⁶. No source we found gives the production go-live date. Test your connection early.

Only the first operator files. Downstream operators and traders pass reference numbers along and keep records for at least five years ⁷. Article 33 of the regulation provides for a link between the system and customs, the authority that handles import clearance ⁴. Those numbers let a buyer's file point back to the importer's statement. Buyers should ask for them in the contract. The trade documents checklist in the Ossiano Trade Finance Guide shows where such papers sit in a deal.

1. CollectThe importer asks suppliers for the geolocation of each plot and the date or time range of production ⁴.
2. AssessRisk assessment and mitigation. Brazil and Indonesia are standard risk ^4,8.
3. FileThe statement goes into the Information System, as GeoJSON on a map or in bulk by machine connection ^5,6.
4. NumberThe system returns a reference number and a verification number for the statement ⁶.
5. Pass onOperators pass reference numbers down the chain. Downstream buyers and traders keep records for at least five years ⁷.

The EU Information System is a module of the TRACES platform where operators draw plots on a map, the Commission says ⁵.

05Which tracing tools are in use, and which are still being built?

Tools differ widely in maturity. The figure gives each one a stage and the evidence for it.

The European Forest Institute says operators can compare plot geolocation with satellite images and forest maps at the cut-off date ¹⁰. Suzano, a Brazilian exporter, uses satellite images to track its production areas and check for forest conversion ⁹. Mongabay reported in December 2024 that Suzano was building its own blockchain record. The European Environment Agency calls blockchain in forestry still incipient ¹⁵.

Isotope testing can show where wood grew, and lab tests can identify the wood species. World Forest ID is building a reference collection, led by the Royal Botanic Gardens, Kew ¹³. FSC describes its use of isotope testing as pilot projects ¹⁴. No source we found names a pulp mill or pulp trader that uses these tests as routine.

How real is it?

Six tracing tools, by stage

• In Production
  Satellite and forest map checksSuzano uses satellite images to track production areas and check for forest conversion ⁹. The European Forest Institute describes the method ¹⁰.
• In Production
  Digital maps of wood originMetsa Group says it has used digital maps to monitor wood origin for more than ten years ¹². Whether it meets the six-decimal rule is not stated.
• In Production
  RFID tags on logsThe European Environment Agency says RFID has gained some traction in Scandinavian countries for wood-log monitoring. It gives no figure for the extent ¹⁵.
• Being Built
  Suzano blockchain recordMongabay reported in December 2024 that Suzano was developing it in-house. We found no 2026 update ⁹.
• Being Built
  World Forest ID reference libraryLed by the Royal Botanic Gardens, Kew. It is building a geo-referenced collection of wood samples for isotope and species tests ¹³.
• Pilot
  FSC use of isotope testingFSC presents isotope testing as pilot projects and case-by-case investigation support ¹⁴. We found no pulp user.

Stage labels: In production (commercial plants running), Being built, Planned (announced, not yet built), Pilot (test plant), Lab (research only), Stopped (closed or cancelled). Stages are as of the date of each source. Company claims are marked as such.

06What does it cost, and who faces the full process?

Mongabay reported in December 2024 that Ibá, the Brazilian tree industry body, estimates the rule will add $40 to $230 a ton of pulp, depending on the size and complexity of the supply chain ⁹. This is a paraphrase of an industry estimate, made before the 2025 simplifications, and it may be out of date ⁹. No source we found gives a measured cost.

The rule also depends on the origin. The Commission lists Canada, Chile, Uruguay, the United States, Finland and Sweden as low risk. Brazil and Indonesia sit at standard risk ⁸. For wood from low-risk countries only, the importer does not need the risk assessment and risk mitigation steps, but it still collects the information and files the statement ⁴. Pulp from Brazil and Indonesia needs all three steps. For how fast trees grow in the north and the south, see the tree race. For the European buyer's wider position, see Europe: maker, buyer and rule-maker.

For a trade lender, plot data is also a commercial risk input. A cargo that cannot be placed on the EU market carries buyer and country risk, see buyer, country and performance risk. The same data supports KYC checks, see know your customer in trade finance, on the exporter.

What this means for traders

• Treat an FSC or PEFC certificate as supporting evidence. Ask each supplier for plot coordinates and the dates of production as well.
• Put reference numbers and five-year record keeping into supply contracts before December 30, 2026.
• Check the current Annex I and your origin's risk tier. Pulp from Brazil and Indonesia needs the full process.

Questions traders ask

Does FSC or PEFC certification meet the EU Deforestation Regulation?

No. The regulation says certification may be considered as complementary information in the risk assessment. The importer still has to collect plot geolocation and file a due diligence statement.

When does the EUDR apply to pulp?

The main obligations apply from December 30, 2026. Micro and small companies, and natural persons, follow on June 30, 2027.

What format does the geolocation data need?

The Commission's API reference says GeoJSON, with latitude and longitude to at least six decimal digits. Plots above 4 hectares need a polygon.

How long must due diligence records be kept?

Five years. For operators the period starts when the product is placed on the EU market or exported.

How much does EUDR compliance cost per ton of pulp?

Mongabay reported in December 2024 that the Brazilian industry body Ibá estimates $40 to $230 a ton of pulp, depending on supply chain size and complexity. This paraphrases an estimate made before the 2025 simplifications, so it may be out of date.

Read next

• Makers and buyersEurope: maker, buyer and rule-maker
• Money and rulesPulp watch: every rule and date in one place
• Inside the millThe tree race: 7 years in Brazil, 60 to 80 in Finland
• Makers and buyersBrazil: can the largest pulp exporter keep growing?
• Makers and buyersIndonesia: Asia's hardwood supplier
• Makers and buyersChina: the largest buyer is building its own mills
• Ossiano Trade Finance GuideHow each trade finance instrument works
• GlossaryTrade finance terms in plain English

Importing pulp into the EU or financing a cargo with EUDR exposure? Ossiano Capital works on trade finance for pulp and paper trades.

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Sources and notes

1. PEFC International, Global Statistic sheet, December 2025 (total certified area and chain of custody certificates). https://cdn.pefc.org/pefc.org/media/2026-02/7e0d5bbb-922e-4a5f-bc9b-6796b9504b1d/eb326a73-d85a-532e-bb77-0280717ff4eb.pdf
2. FSC UK, Facts and figures (certified hectares and chain of custody certificates; map caption August 2025), read October 27, 2026. https://www.uk.fsc.org/what-is-fsc/facts-and-figures
3. European Commission, Understand due diligence, EUDR implementation pages (Green Forum), read October 27, 2026. https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/understand-due-diligence_en
4. EUR-Lex, Regulation (EU) 2023/1115, consolidated text as at December 26, 2025 (Articles 2, 3, 4, 9, 10, 12, 13, 25 and Annex I). https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20251226
5. European Commission, Information System Deforestation Regulation, Green Forum, read October 27, 2026. https://green-forum.ec.europa.eu/deforestation-regulation-implementation/information-system-deforestation-regulation_en
6. European Commission, EUDR Operator API Reference v1.0, released May 29, 2026. https://eudr.webcloud.ec.europa.eu/tracesnt/help/eudr-documentation/operator/pdf/EUDR Operator API Reference v1.0.pdf
7. EUR-Lex, Regulation (EU) 2025/2650 of December 19, 2025 amending Regulation (EU) 2023/1115 (application dates, downstream operators and traders, records). https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R2650
8. EUR-Lex, Commission Implementing Regulation (EU) 2025/1093 of May 22, 2025 (country benchmarking: low, standard and high risk). https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R1093
9. Mongabay, Brazil paper and pulp industry invests in blockchain to comply with EUDR, December 2024 (Suzano monitoring and blockchain; Ibá cost estimate, paraphrased). https://news.mongabay.com/2024/12/brazil-paper-and-pulp-industry-invests-in-blockchain-to-comply-with-eudr/
10. European Forest Institute, Insight: Geolocation and the EU Deforestation Regulation, December 2025. https://efi.int/sites/default/files/files/flegtredd/TF/Documents/Insight%20-%20Geolocation%20and%20the%20EUDR%20Dec25.pdf
11. UPM, Origin of wood statement, UPM Fray Bentos pulp mill, issued February 6, 2026 (data for 2025). https://www.upm.com/siteassets/certificate-finder/statements/origin-of-wood-statement---upm-fray-bentos-pulp-mill.pdf
12. Metsa Group, We know the origin of the wood we use, read October 27, 2026. https://www.metsagroup.com/sustainability/forests-and-wood/origin-of-wood/
13. Royal Botanic Gardens, Kew, World Forest ID, undated page. https://www.kew.org/science/our-science/projects/world-forest-id
14. FSC, Wood ID, undated page. https://fsc.org/en/wood-id
15. European Environment Agency, Forest Information System for Europe, Timber traceability: pioneering innovation to eradicate deforestation from Europe's supply chain, undated. https://forest.eea.europa.eu/resources/research-corner/research-highlights/timber-traceability-pioneering-innovation-to-eradicate-deforestation-from-europes-supply-chain
16. EUR-Lex, Delegated Regulation (EU) 2026/2102 of July 13, 2026 (act page: date and entry into force September 18, 2026; Annex I not read by us). https://eur-lex.europa.eu/eli/reg_del/2026/2102/oj
17. Forest Stewardship Council, How the FSC System Works, read October 17, 2026. https://fsc.org/en/how-the-fsc-system-works
18. PEFC International, Discover PEFC, read October 17, 2026. https://pefc.org/discover-pefc

Trade figures come from UN Comtrade (2015 to 2025, as reported by 10 countries) and FAOSTAT (1961 to 2024), checked and recalculated by us; each chart names whose data it uses. All tons are metric tons. All facts on this page are as of October 27, 2026, the date of publication, and may have changed since. For rules and tariffs, check the pulp watch before you act.

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