Policy for avoiding greenwashing

FSC has invited all interested stakeholders to submit their feedback before 1 July 2009.

Greenwashing - a key concern

Since the early days of FSC, the organisation has worried about companies using the FSC name for greenwashing bad business practice.

The draft policy on association is the latest in a long series of attempts to address this issue.

The fear is that companies may certify a minor share of their business and use that for public communication while they are involved in controversial management practices in other parts of their business.  

Definition of controversial activities

The policy defines 6 categories of controversial activities which are considered unacceptable for companies associated with FSC:

a) Illegal logging or trade in illegal wood or forest products 
b) Violation of traditional and human rights in forestry operations 
c) Destruction of high conservation values in forestry operations 
d) Significant conversion of forests to plantations or non-forest use 
e) Introduction of genetically modified organisms in forestry operations 
f) Violation of any of the ILO Core Conventions 

The first 5 points are familiar to those working with the FSC Controlled Wood standards, while the last point has been added based on a motion from the FSC General Assembly 2008 (more info at www.ilo.org/declaration).

Proposed rules too obscure

The intent of the policy has broad support from stakeholders in the FSC community, for good reasons: It is clearly not acceptable to use FSC's good name for greenwashing. However, reading the policy through we find that it tends to raise more questions than answers.

It describes new procedures for screening of organisations applying for a trademark license, by authorized trademark agents. In case of doubt the information is forwarded to an “FSC Brand Management Committee”, which then takes the decision. This decision can be further appealed to the FSC Board. 

Unfortunately, the policy does not include any information on how the screening shall take place and how serious a violation shall be in order for a company to be excluded from using the FSC logo. Is one piece of illegal wood found in a store of a multinational Do it Yourself chain enough to terminate the trademark license for the all stores and related companies? In theory, this could be the case according to the policy – but we doubt that this is the intention. The policy gives no indication of thresholds for violations in order to terminate the license, nor does it explain for how long violators should be banned from using the FSC trademarks.

Does the policy match a real need?

Another question is how big the problem is and hence the need for the policy. Is greenwashing frequently taking place and can it not be addressed by the current rules, which  are already quite strict? A few years ago, FSC dissociated itself formally from the company Asian Pulp and Paper (APP), based on controversial issues. Are there other cases which have been impossible to address using the existing rules? We are not aware of them. Is it really necessary to establish a new complicated system for screening all organisations using FSC trademarks? 

The status of the document is “Final Draft”, which in FSC terminology means that it is ready for board decision. However, it seems premature to launch the policy before the above issues have been addressed and clarified.