13.1 A recognised but limited role
Article 10(2)(n) allows information from certification and third-party verification schemes to be used in the risk assessment, provided it meets the requirements of Article 9. The Guidance (section 10) is emphatic:
- the EUDR does not require operators to use certification, producers to join a scheme or countries to create one;
- certification is not a green lane: it does not replace the operator's due diligence, and the operator remains responsible;
- self-declaration schemes, without third-party certification, fall outside this guidance and are by definition less robust;
- certification may be used to satisfy only part of the requirements.
13.2 How to assess a scheme
The Guidance proposes three blocks of analysis, to be reassessed regularly:
| Block | What to examine |
|---|---|
| 1. The standards themselves | Validity, authenticity and scope (does it cover the EUDR commodities and products?); alignment with the definition of deforestation-free and with the 31/12/2020 cut-off date; assessment of the risk of illegality and of deforestation; traceability with geolocation down to the plot; whether the chain-of-custody model allows known and unknown origin to be mixed; whether it allows mass balance; the ability to supply the Article 9 information with verifiable evidence |
| 2. Implementation | Accessibility of governance information and audit summaries; a public database of certificates (scope, validity, suspensions); periodic, random and independent checks; control of the quantity and origin of materials, including by anatomical, chemical or DNA analysis; effective volume control; use of similar labels for different schemes; substantiated reports of shortcomings in the scheme or among its participants |
| 3. Governance | Conflicts of interest; fraud and corruption controls; compliance with ISO or European standards; penalties, suspensions and how quickly certificates are revoked; stakeholder engagement and the inclusion of smallholders; the independence of accredited certification bodies and the views of other parties (trade unions, civil society, NGOs) |
13.3 Mass balance and partial certificates
Products certified under mass balance, or carrying a percentage of certified material, are not compliant with the EUDR. Where the chain of custody allows certified and non-certified material to be mixed, the operator must obtain information about the controls over the non-certified share, and due diligence must cover the product as a whole (Guidance, section 10.a, notes 17 and 18).
Chain-of-custody certification traces the product back to the previous entity, not to the place of origin; when relying on it, the operator must ensure that all the material complies with the EUDR (note 19).
13.4 Mandatory public schemes and the repository
The Guidance notes that mandatory public verification schemes may achieve high standards of coverage and enforcement, provided they cover all operators in the country, and may integrate smallholders better. The Commission will create a repository of certification schemes, with transparent information on the scope of each, for operators and authorities to consult. In the renewable energy field, low ILUC-risk certification schemes (Delegated Regulation (EU) 2019/807) may also supply part of the Article 9 information (FAQ 9.12).