This project evaluates the factors driving improvement of industry-sponsored private regulatory standards under conditions of competition in three-country contexts between 1995 and 2005. The paper provides a comparative analysis of regulatory competition in forestry in the USA, Sweden and Finland. While previous research has identified the importance of transnational supply chain pressure and of NGOs’ direct targeting campaigns in diffusing and upgrading standards, this paper stresses the role of public comparison and environmental benchmarking that contributed to an upgrading of industry standards via competition between the Forest Stewardship Council and rival industry-sponsored schemes. The paper explores how transnational and national actors created important moments of public comparison in which substantive as well as accountability standards were ratcheted up while they diffused more broadly across industry. This project evaluates the role of environmental benchmarking in constructing and contesting the legitimacy of private regulation.