ESTS Granted for FSC™ Controlled Wood (CW) and FSC™ Regulatory Module (RM) Scope Extension

In July 2026, ASI formally notified ESTS (FSC-A000543) in writing, confirming the granting of two technical sub-scope extensions:

• FSC Controlled Wood​

• FSC Chain of Custody Regulatory Module

ESTS, part of the Cotecna Group (FSC-A000552), has held FSC accreditation since June 2019. Following this scope extension, the product standards under which ESTS can deliver certification include:

• FSC-STD-40-003 (Multi-site Chain of Custody)

• FSC-STD-40-004 (Chain of Custody)

• FSC-STD-40-004r (Regulatory Module – FSC Chain of Custody)

• FSC-STD-40-005 (Sourcing of Controlled Wood)

• FSC-STD-40-006 (Project Certification)

• FSC-STD-40-006r (Regulatory Module – Project Certification)

• FSC-STD-40-007 (Sourcing of Reclaimed Materials)

Beyond FSC, ESTS also holds ASI recognition for RSPO Supply Chain Certification and MSC Chain of Custody Certification.

I. What is the FSC Regulatory Module (RM)?

In a nutshell: the FSC RM is a voluntary add-on module developed by FSC specifically to help certificate holders align with the EU Regulation on Deforestation-free Products (EUDR, Regulation (EU) 2023/1115).

A critical boundary to understand:

Certification bodies assess a company's conformity with RM requirements. The final determination of EUDR compliance rests with the competent authorities of EU member states.

Any claim that "implementing RM equals obtaining an EUDR pass" is inaccurate. The value of RM lies in using a standardized, third-party verifiable approach to prepare and communicate the information that EU customers require.

The framework established under RM covers three key areas:

1. Establish a Due Diligence System (DDS) to support EUDR compliance

Covering information collection, risk assessment, and risk mitigation.

2. Collect and communicate precise product origin information

Including geographic location and production time. "Geographic location" is strictly defined: latitude and longitude coordinates of the plot, accurate to at least six decimal places.

3. Ensure that only deforestation-free material enters the FSC Chain of Custody

Two key characteristics:

It is an add-on, not a replacement. RM sits on top of existing FSC Forest Management, Chain of Custody, Project and Controlled Wood certifications — it cannot exist independently. In other words, a company must first hold (or simultaneously apply for) an FSC CoC certificate before it can implement RM.

It is independently assessed by a certification body. FSC-accredited certification bodies (such as ESTS) assess the company's compliance with the module requirements, providing an additional layer of independent assurance.

II. Why would some FSC-certified companies exporting to Europe pursue RM?

Pursuant to the Regulation (EU) 2025/2650 published in December 2025:

• 30 December 2026​: EUDR applies to large and medium-sized operators and traders

• 30 June 2027:​ EUDR applies to small and micro-enterprises

On 4 May 2026, the European Commission published the statutory simplification review report. Alongside a set of simplification measures (expected to reduce annual compliance costs for businesses by approximately 75%), the report sent two clear signals: core EUDR legislative text will not be reopened, and the existing implementation timeline remains applicable.

In other words, the waiting period is over.​ As of publication of this article, only four months remain until 30 December 2026.

Three Common Misconceptions

Misconception 1:​ "EUDR is an EU matter and irrelevant to Chinese suppliers."

From a legal entity perspective, Chinese exporters are typically not "operators" under the EUDR. But their EU buyers are. Before placing products on the EU market, EU buyers must submit a Due Diligence Statement (DDS). The plot-level geolocation coordinates, date of production, country of origin, tree species, and other information required for the DDS can only be passed down the supply chain tier by tier — ultimately it has to land with you.

Failure to provide this data may not trigger direct fines for you but it will lead to lost orders.

Misconception 2:​ "I have an FSC certificate, so I’m already EUDR-compliant."

Not true. FSC CoC certifies a company's chain-of-custody control capability. Its original requirements do not cover the plot-level geolocation data, date of production records, or deforestation-free statement transmission required by EUDR. This is precisely why FSC needed to develop the additional Regulatory Module — if CoC alone were sufficient, RM would serve no purpose.

Misconception 3:​ "EUDR has been postponed twice, so let's wait and see."

The two previous delays were driven by concerns over EU IT system readiness and the administrative burden on SMEs. Both issues were addressed through simplification measures in the December 2025 revision, and the May 2026 review report confirmed that the core text would not be reopened. The cost of continued waiting is that the time left to build your own supply chain data system keeps shrinking.

What RM can do for You?

• Standardize scattered supply chain information.​ Geographic location, date of production, risk assessment, and mitigation measures are collected and communicated under a unified framework, rather than preparing a new set of forms for every customer.

• Provide third-party independent assurance.​ There is a difference in how EU buyers perceive your claim that the data is reliable versus the same claim assessed by an FSC-accredited certification body.

• Enable usable claims.​ Under RM, there are two types of claims: Regulatory (REG)​ and Regulatory+ (REG+). REG+ requires a "fully verified supply chain" — meaning every certificate holder across the supply chain has implemented RM and established the corresponding product group.

Reduce the risk of order disruption.​ When EU customers begin screening supplier data capabilities one by one from late-2026 onwards, those who have completed RM certification will rank significantly higher.

III. Which companies should prioritize action?

If any of the following apply to you, we recommend initiating an assessment promptly:

• Your products are exported directly or indirectly to the EU market and fall within EUDR-covered commodity scope (timber and timber products, etc.)

• Your EU customers have already begun requesting geolocation coordinates, date of production, or supply chain traceability information

• You already hold an FSC CoC certificate and wish to build compliance capability on top of your existing system

• Your supply chain has multiple tiers and involves multiple source countries, making manual compilation increasingly unmanageable

• You plan to expand your share of exports to Europe before 2027

To learn more details, or to request a quote, feel free to contact us.

About ESTS

Extensive Standard Technical Services Co., Ltd. (ESTS) is a global certification body and audit firm with professional services covering social compliance, sustainability, green and low carbon, food safety, quality system, etc. We are committed to enhancing the ESG (Environmental, Social and Governance) competitiveness for brands and retailers supply chains, as well as to creating a transparent and reliable supply chain for our clients.

About Cotecna

For over 50 years, we have been supporting agriculture, food and pharma, minerals and metals, and consumer products supply chains all over the world. We provide testing, inspection, and certification services to help our clients navigate evolving regulations, ensure product compliance, and support their sustainability journey.