By Maria Chiara Ferrarese, CONFORMA Board Member and CSQA General Manager
Regulation (EU) 2023/1115 on deforestation and forest degradation (EUDR) represents one of the European Union’s most significant legislative measures concerning the sustainability of supply chains.
From 30 December 2026 for large and medium-sized companies, and from 30 June 2027 for small enterprises, operators placing on the market or exporting products associated with commodities considered to be at risk of deforestation will have to demonstrate that those products do not contribute to deforestation, are not associated with forest degradation and comply with the applicable legislation in the countries of production.
This represents a step that goes beyond mere regulatory compliance.
For the first time in such explicit terms, the European legislator is requiring companies to take an active role in understanding, monitoring and managing risks throughout the entire supply chain, assigning them direct responsibility for collecting, assessing and retaining the information needed to demonstrate product compliance.
OPERATOR ACCOUNTABILITY
The EUDR has a particularly significant feature.
The Regulation does not make third-party certification mandatory, nor does it require compliance to be certified in advance by an independent body.
Instead, it places responsibility on the economic operator to collect information, carry out the risk assessment and prepare the Due Diligence Statement, assuming full responsibility for the claims made therein.
This approach is consistent with the evolution of European regulation, which is increasingly moving towards models based on accountability and the direct responsibility of economic operators.
However, the greater the significance of the statements made by companies, the more important it becomes to demonstrate that they are well-founded.
THE CRUCIAL ISSUE: CREDIBILITY
Ultimately, every compliance system relies on the quality of the information available.
In the case of the EUDR, evidence may come from multiple parties operating across global supply chains that are often highly complex and interconnected.
Information concerning the origin of commodities, the geolocation of plots of land, the traceability of flows, legal compliance and production practices must be collected, kept up to date and made available to the competent authorities.
The issue, therefore, is not simply one of operators acting in good faith. More importantly, it concerns their actual ability to ensure that the information used to support their statements is accurate, complete, relevant, verifiable and reliable.
In other words, the question becomes unavoidable: who guarantees the reliability of the information on which these statements are based?
THE VALUE OF INDEPENDENT ASSESSMENT
Over time, modern market economies have developed numerous tools designed to increase confidence in the information used in decision-making processes.
Financial auditing, accreditation, certification, inspection and independent verification are all based on a well-established principle: trust increases when statements are subject to assessment by competent, impartial and independent third parties.
This is not because organisations are unable to assess themselves, but because the credibility of a statement increases when the process that generated it is subject to external verification.
This is the principle of third-party independence, one of the fundamental pillars of the European quality infrastructure and conformity assessment system.
A TRUST INFRASTRUCTURE FOR THE MARKET
The European Commission Guidelines recognise that certifications, audits and independent verification can provide useful evidence as part of the information-gathering and risk-assessment processes required under the EUDR.
Although these tools do not replace the operator’s responsibility, they can help strengthen the quality of the available evidence and the robustness of the due diligence process.
Their value, however, goes beyond simply providing documentary support.
Independent assessment represents a genuine trust infrastructure, enabling markets, institutions and stakeholders to place greater confidence in the environmental and sustainability information associated with products, organisations and supply chains.
In a context characterised by growing attention to transparency and sustainability, the role of third parties is to reduce uncertainty, strengthen the credibility of information and increase confidence in the evidence supporting companies’ statements.
A CULTURE OF DEMONSTRATION
The importance of objective evidence is not limited to the EUDR.
The same direction can clearly be seen in the evolution of European and national legislation concerning environmental communication and the fight against greenwashing.
Italian Legislative Decree No. 30 of 20 February 2026, adopted to implement Directive (EU) 2024/825, reinforces the principle that environmental claims addressed to the market must be based on objective, verifiable evidence that is sufficiently robust to substantiate them.
The underlying principle is the same: making a claim is no longer enough; it must be possible to demonstrate it.
Sustainability cannot be based solely on communication. It must be supported by documented, traceable and verifiable information.
For this reason, the distinction between declaring and demonstrating is becoming one of the central themes of European policies on sustainability, transparency and consumer protection.
In this context, independent verification takes on a role that goes beyond technical control and becomes a practical due diligence tool.
Assessments carried out by competent and independent third parties can help strengthen the reliability of the evidence collected, reduce the risks of errors, omissions or disputes, and demonstrate that diligent and proportionate measures have been adopted to validate the information used to support environmental claims.
THE ROLE OF VOLUNTARY SCHEMES
In this context, voluntary certification, verification and inspection schemes are becoming increasingly important. They do not replace the obligations laid down by the EUDR, nor do they transfer responsibility for compliance to other parties.
Operators remain solely responsible for the statements they make to authorities and the market.
Voluntary schemes can, however, perform an essential function: introducing an additional layer of reliability, transparency and independent oversight throughout the supply chain.
Their relevance does not derive from being a regulatory requirement, but rather from their ability to provide companies, authorities, investors and consumers with greater assurance regarding the quality of the information used to demonstrate compliance and support sustainability claims.
A CONSIDERATION THAT GOES BEYOND THE EUDR
The EUDR is probably only one of the first manifestations of a trend that is likely to affect a growing number of economic sectors.
Organisations are being called upon to produce ever-increasing amounts of environmental, social and governance information, while authorities, investors, customers and consumers are demanding ever-higher levels of transparency, reliability and verifiability.
In this context, the distinction between declaring and demonstrating takes on strategic importance.
The competitiveness of companies will increasingly depend on their ability to support their claims with solid, documented and verifiable evidence.
Trust does not arise from statements in themselves, but from the credibility of the information and the robustness of the processes that generate it.
Certification, inspection, verification and other forms of third-party conformity assessment therefore represent not merely technical control tools, but genuine mechanisms serving the public interest by supporting trust in markets.
In a regulatory environment that requires organisations to exercise increasingly advanced forms of due diligence over environmental and sustainability information, independent assessment helps strengthen the credibility of evidence, reduce uncertainty and support stakeholder confidence in the information underpinning increasingly important economic decisions.
The real evolution taking place is not simply the transition from compliance to sustainability. Above all, it is the transition from declaration to demonstration. And throughout this process, independent assessment continues to represent one of the most effective tools available to the economic system for ensuring assurance, reliability, transparency and trust.
(Source: EticaNews)