The new year brings several important regulatory and standard-related developments that companies operating in forestry, wood-based supply chains, renewable energy, and sustainable materials should be aware of.
Below, we provide an overview of the main topics to keep in mind in the coming year.
FSC Chain of Custody:
Updated Controlled Wood Risk Assessment
FSC will soon publish an updated Controlled Wood Risk Assessment.
Please note that the existing CWRA dashboard will be gradually phased out, as current risk assessments are replaced with revised ones. For each country, the existing risk assessment will be replaced six months after the publication of the corresponding updated risk assessment. Companies are therefore advised to closely monitor updates relevant to their sourcing countries and prepare for changes in risk categorisation.
New risk assessment:
- defines risk levels for controlled wood in Estonia,
- influences the need for risk mitigation measures,
- helps ensure compliance with FSC Controlled Wood requirements.
Clarifications regarding contractors and core labour requirements (ADVICE-40-004-23 V2-0)
It is important for FSC Chain of Custody certificate holders to also note the implementation of ADVICE-40-004-23 V2-0, which addresses the evaluation of contractors against the FSC core labour requirements. This guidance applies to all FSC Chain of Custody certificate holders and applicants who use non-FSC-CoC-certified subcontractors in their Chain of Custody (e.g., storage, logistics, transportation services).
The guidance came into effect on November 1, 2024, with a transition period lasting until December 31, 2025. According to the guidance, organizations must:
- include non-FSC-CoC-certified contractors in their self-assessment system;
- ensure that contractors’ compliance with FSC labor requirements is assessed and documented (including through first, second, or third-party audits, if necessary);
- retain audit evidence that can be assessed by the certification body during risk assessment.
Revision of the FSC Chain of Custody Standard (FSC-STD-40-004)
FSC is currently revising the FSC Chain of Custody standard (FSC-STD-40-004). The purpose of public consultations and stakeholder engagement is to update the standard in line with changing market and regulatory expectations.
The revision process has introduced:
- the schedule and scope of the update,
- the goal of publishing the updated standards by January 2027,
- and setting their effective date as July 2027.
For companies, this means that changes in documentation, processes, and audit requirements can be expected in the coming years, and it is worth starting preparations early.
FSC Forest Management:
FSC Forest Stewardship Standard for Estonia
After a long development process, the new FSC Forest Stewardship Standard for Estonia has been published.
- Effective date: January 1, 2026
- Transition period: 18 months
This means that FSC forest management certificate holders must transition to the new standard by the end of the transition period at the latest. The new standard specifies environmental, social, and economic requirements and requires a conscious and planned transition.
EUDR:
Postponement of implementation and new deadlines
The implementation of the EUDR has been postponed, giving companies additional time to prepare. At the same time, clarified and amended requirements have been published, concerning, among other things:
- due diligence systems,
- risk assessment and mitigation,
- data collection and storage.
Although the deadlines have been postponed, it is not worth delaying preparations – the complexity of the requirements calls for a well-thought-out and systematic approach.
ISCC:
Updated ISCC PLUS Documents
ISCC has published updated ISCC PLUS documents, which replace previous versions.
The updated documents:
- are valid from November 13, 2025,
- become mandatory from January 1, 2027.
The changes include, among other things, mass balance accounting principles, calculation methodology, and clarifications on the implementation of the standard. Certificate holders are advised to assess the impact of the changes on their existing systems in a timely manner.
SBP:
Final RED III Risk Assessment
The Sustainable Biomass Program (SBP) has published its final RED III Level A risk assessments, which are essential for organizations supplying biomass under the EU Renewable Energy Directive (RED III).
The risk assessment:
- supports the assessment of compliance with RED III sustainability requirements,
- helps clarify which risks are assessed as low,
- affects the scope of audits and the need for risk mitigation measures.
The new year brings several important changes to certification schemes and the regulatory framework for companies. Early awareness, preparation, and a systematic approach will help you ensure a smooth transition and avoid compliance risks.
Our goal is to support you in understanding and implementing these changes – from interpreting requirements to audits and certification.
If you want to know how these changes will affect your business, feel free to contact us.