Insights from benchmarking CSLs against sustainability, robustness and EUDR requirements using the Comparative Benchmarking Tool

As the European Union's Deforestation Regulation (EUDR) implementation deadline approaches, companies across global supply chains face new challenges. Products like soy, palm oil, and rubber must now be proven ‘deforestation-free’ before entering the EU market. For many businesses, certification schemes seem like a helpful solution, for others, it may even be the only viable option. This is particularly true in high-risk sourcing regions, where certification often becomes the only viable tool available if a company is committed to maintaining supply chains in these areas.

Certification schemes have been common in global trade for years. They typically track products from farm to store, checking environmental practices and social standards along the way. Given the approaching implementation deadline for EUDR, it is important to understand how certification is aligned to the regulation’s requirements to properly guide businesses in their due diligence efforts. During our work in Work Package 4 (WP4), we have developed a Comparative Benchmarking Tool (CBT) that not only assesses coverage of sustainability issues but also looks into material control rules along the supply chain and the assurance and governance elements that underpin a robust certification system. The following article describes our experience with developing and implementing the Comparative Benchmark Tool (CBT) as well as key findings in our evaluation.   

Developing the Comparative Benchmark Tool

At Preferred by Nature (PbN), we developed the CBT to evaluate certification schemes against sustainability and EUDR requirements for the HARMONITOR Project. This tool builds on our Sustainability Framework and our previous experience examining certification schemes for the EU Timber Regulation. The first version of the framework incorporated sustainability requirements and system requirements, including material control, assurance, and governance aspects that make a system robust. Our work in WP4.1, supported by our partners from DBFZ, Utrecht University and RINA-C, focused on refining the framework by conducting desktop research and a systematic review of 22 CSLs in the EU bioeconomy. A collaborative workshop with project partners contributed to identifying key indicators and the final design of the CBT. We also developed the methodology to use for the implementation of the framework.

Implementing the framework and lessons learned

In WP4.2, we benchmarked 10 selected certification schemes against the Comparative Benchmarking Tool with the help of partners RINA-C, Utrecht University and Agrovet. The methodology presented a step-by-step guidance on how to conduct the benchmark and considerations when assigning conclusions.  

We engaged directly with the certification schemes, sharing our preliminary findings and incorporating their feedback in WP4.3. This collaborative process enhanced the accuracy of the results and ensured that our assessment reflected the most current state of each scheme's requirements and capabilities. Throughout the benchmarking implementation, we encountered several challenges that required revisions:

1. Consistency in evaluation: A level of subjectivity is always expected when evaluations are conducted by different people. This was observable, for example, between the use of intent covered versus partially covered, not covered versus not applicable. A revision in consistency addressed these issues, establishing clearer parameters for assigning conclusions.

2. Legality indicator coverage: Addressing legal issues comprehensively is key in any EUDR alignment effort. Therefore, a general statement that all laws should be complied with is considered not sufficient. The revision in consistency considered a specific legality check covered only when it was explicitly required in the scheme’s documentation.

3. Evolving standards: Certification schemes have updated their system documentation as a response to the EUDR during and after completing the evaluations. We saw the need to open the benchmarks and incorporate these changes into our evaluations. This required additional work to assess the FSC's Regulatory Module, RSPO's updates, RTRS's Model IV alignment with EUDR Chain of Custody, SBP's DTS EUDR module, and ISCC's EUDR Add-on.

These challenges provided valuable lessons that continue to inform the development of our benchmarking approach.

What certification does well

Many certification frameworks show strong coverage of core human rights standards. For instance, they often include basic protections to prevent child labour, forced labour, and discrimination. Several also prioritize responsible chemical use, waste management, and biodiversity conservation. In many sustainability issues, schemes can mirror or exceed national legislation. These strengths reflect years of development and stakeholder input, which have led to stricter auditing protocols and increasingly transparent governance.

Operators sourcing commodities that fall under EUDR requirements may find real value in these schemes' emphasis on environmental stewardship and worker protections.

Regarding legality, most schemes effectively cover land use rights and Indigenous peoples' protection, with requirements for legal documentation of land tenure and implementation of Free, Prior, and Informed Consent processes. They generally include grievance mechanisms that allow affected communities to raise complaints without retaliation. For corruption prevention, many schemes have developed conflict-of-interest policies and mandatory disclosures, though approaches vary in comprehensiveness and direct mechanisms to track corruption sanctions.

With regard to deforestation, schemes have established requirements prohibiting deforestation of natural forests with a stricter cutoff date than the EUDR. Most have established requirements prohibiting deforestation but may not fully address deforestation of all forest types or forest degradation as defined by the regulation.

Regarding traceability, certification schemes have made significant progress in developing digital tools that collect and transfer supply chain information. These systems typically offer geolocation data collection from production plots, though the extent of implementation varies. Many schemes offer chain of custody options like segregation and controlled mass balance to maintain product integrity. Operators conducting due diligence need to give special attention to supply chain models that allow mixing of non-conforming material, given this is not allowed in EUDR.

Certification bodies typically handle much of the verification process, applying standardized criteria that can reduce the Operators administrative burden. While certification alone cannot guarantee EUDR compliance, these systems provide important frameworks for operators to build upon when conducting due diligence.

Certification is not a green lane for EUDR compliance

Certification does not guarantee compliance with the EUDR. Under the regulation, companies must independently confirm that their commodities are deforestation-free, align with relevant national laws, and have traceability that pinpoints the exact plots of land involved. While certification can alleviate much of the workload, it does not replace a company's own responsibility to perform due diligence – but may be the best solution available.

One limitation is that some certification systems do not always systematically verify compliance with every law in the country of origin. Their emphasis can sometimes be more on environmental improvements or market-driven sustainability goals than on legal verification. Tax, anti-corruption, trade, and customs regulations are, for example, commonly missing checks. Consequently, even if a product carries a sustainability label, it may not have been explicitly checked against all relevant laws—an important consideration under the EUDR's definitions of legality and deforestation-free production.

The Guidance Document for EUDR and the Comparative Benchmarking Tool

Chapter 10 of the Guidance Document for EUDR addresses the role of certification and third-party verification schemes in risk assessment and risk mitigation. We noted that many elements in the Guidance Document were already incorporated into our framework. Our assessment methodology already addressed alignment with ‘deforestation-free’ definitions and the December 31, 2020 cut-off date, material control systems, scheme governance and stakeholder engagement processes. We had also evaluated transparency mechanisms, independent verification procedures, conflict of interest prevention, corruption monitoring, international standards implementation, smallholder participation, and accreditation procedures. The Commission's document also emphasized aspects like the availability of free and publicly accessible databases and the transparency of audit summaries, reaffirming the importance of elements we had already incorporated into our work.

However, the guidance also highlighted areas where our framework could be enhanced, which we are now strengthening through ongoing benchmarking projects.  For example, we recognize the need for deeper evaluation of mixing risks under different supply chain models. As one example of strengthening our framework and methodology, we are currently conducting evaluations that allow differentiation under different supply chain models, based on specific certification system claims.

Critical issues identified

Our benchmarking revealed several critical issues that certification schemes are addressing with varying levels of success:

Traceability requirements:

The EUDR places significant emphasis on the traceability of commodities to ensure they are sourced from deforestation-free regions. This requires the transfer of exact geolocation data of production plots throughout the supply chain.

While FSC, ISCC, and SBP have developed tools like FSC Trace (using blockchain), the ISCC EUDRx Tool, and SBP's Data Transfer System to facilitate this, others are lagging. For example, RSPO certified mills must hold geolocation data for palm fruit, but this information is not routinely shared along the supply chain. While RSPO launched ‘Prisma’ in early 2025 to improve traceability, their own gap analysis indicates further adaptation is needed to fulfil due diligence obligations.

Corruption prevention

Corruption stands as a critical concern that can undermine deforestation efforts. FSC, ISCC, and RTRS explicitly require corruption checks starting at the farm level. SBP requires a risk assessment from Supply Chain Maps to evaluate national-level issues such as corruption. However, RSPO does not currently address corruption in either its farm-level or chain of custody standards.

At the system level, schemes vary in their approach. ISCC, FSC, and SBP employ conflict-of-interest policies, mandatory disclosures, and due diligence steps to ensure top-level accountability. In contrast, RSPO and RTRS rely more on stakeholder reporting, ethical guidelines, and post-complaint processes.

Forest definitions and degradation

FSC and SBP definitions of forests, deforestation, and degradation already align fully with EUDR requirements. However, ISCC's definition of forest relies on a one-hectare threshold, whereas the EUDR applies to areas of at least 0.5 hectares, meaning the EUDR's forest definition is broader.

Similarly, RSPO employs an HCV/HCS approach but lacks an explicit forest definition. A recent RSPO gap analysis acknowledges the need to align or expand its forest definition to meet EUDR standards, particularly concerning plantation forests which have not been considered relevant by RSPO yet.

RTRS prohibits deforestation of natural forests and sets minimum allowable levels of deforestation, but this does not fully align with the EUDR’s definition of forests, and a recent update to its chain of custody standard does not expand the scope of deforestation covered.

The ongoing evolution of the CBT

The Comparative Benchmark Tool continues to evolve as new guidance emerges and as we participate in multi-stakeholder benchmarking programs. Time constraints limited our ability to incorporate some elements suggested in later guidance, but these inform ongoing iterations of the framework.

Our growing experience benchmarking diverse certification schemes across different supply chains continues to refine the tool, making it increasingly valuable for both regulatory bodies and private entities seeking practical pathways to regulatory compliance.

Moving forward

Certification schemes can take a large part of the workload off organizations that are striving for deforestation-free supply chains. Businesses selling into the EU can also benefit with certification in demonstrating legal compliance, using digital traceability tools that track products and production locations throughout the supply chain, and offer verification that products meet deforestation-free requirements. However, the operator remains responsible for proper due diligence. As more certifications update their requirements to better align with evolving laws like the EUDR, businesses will have stronger tools available—but they must still apply those tools within a comprehensive legal compliance and deforestation-free strategy.

Companies must establish robust internal due diligence systems, conduct regular supplier audits, maintain comprehensive documentation trails, and actively monitor for emerging risks in their sourcing regions.

The success of future certification efforts will depend on the ability of schemes to address these gaps while maintaining their existing strengths in core sustainability areas. As sustainability challenges evolve and the regulatory landscape becomes more complex, regular assessment of certification scheme effectiveness will be crucial for ensuring they remain relevant and impactful tools for promoting sustainable practices across global supply chains.

Want the full details? Dive into the complete HARMONITOR report D4.3, where a wide range of certification schemes are examined in detail, including key findings on how they stack up against EUDR requirements. The report offers a deeper look at specific criteria, governance structures, and ongoing updates, providing a nuanced picture of where certifications excel—and where gaps remain.

Based on the results of the HARMONITOR Project, PbN is hosting a webinar titled ‘How can certification help you comply with the EU Deforestation Regulation?’ on April 24 , all are welcome to register using this link.