FSC ≠ EUDR: Why 70% of Certified Vietnamese Factories Aren't Ready
Key takeaway: FSC and PEFC certify legality and responsible forest management. Neither one collects the GPS geolocation data EUDR requires for every forest plot. Certification and EUDR readiness are two different things.
What FSC and PEFC Actually Prove
FSC and PEFC are chain-of-custody certification schemes. They verify that wood came from responsibly managed forests and moved through a documented, legal supply chain. They are genuinely useful — EUDR's legal documentation layer (S4) treats them as strong supporting evidence.
The Gap: Article 9 Geolocation
What FSC and PEFC do not collect is plot-level GPS geolocation in GeoJSON format — the specific data point Article 9 of EUDR requires for every forest plot feeding into an EU-bound product. Certification schemes were not designed around this requirement, because it didn't exist when most of them were built.
This is precisely why, across early NDI pre-audit assessments, roughly 70% of FSC/PEFC-certified Vietnamese furniture factories still lack EUDR-ready geolocation data — despite being fully certified and, by most measures, well-run operations.
Why This Surprises Certified Factories
It's an understandable assumption: “we're certified, so we're covered.” But EUDR due diligence and forest certification answer different legal questions. Certification answers “was this harvested responsibly and legally?” EUDR additionally asks “exactly where was it harvested, at what coordinates?” — a question certification was never built to answer.
What Closing the Gap Looks Like
Closing it means mapping each Tier 1 and Tier 2 supplier down to the specific forest plot or plantation, then capturing GPS coordinates — a single point for plots under 4 hectares, a closed polygon for anything larger. This is the core of Phase B (Data Collection) in the EUDR Data Package process.
Sources: Regulation (EU) 2023/1115, Art. 9 · NDI Pre-Audit Assessment, HCMC-BD-DN cluster, 2025–2026.