The FSC recently sent out detailed guidance on the interpretation of the FSC Controlled Wood standard.
The guidance is based on a clear need: The first year of field experience with the standard has revealed major inconsistencies in the understanding of the requirements among certified companies and different certification bodies.
Since the controlled wood concept is important for maintaining the overall credibility of the FSC system and consumer trust in FSC products, it is crucial that these rules are well understood and correctly followed by all parties involved. The FSC presents the clarifications in an advice note. Despite the name ‘advice note’, this guidance is mandatory for all companies certified according to the FSC controlled wood standard.
Clients audited by NEPCon should not expect any major changes, since our approach was already very similar to the interpretations now provided by the FSC. We were thus already following the requirements set out in the advice note.
However, the advice note also includes important guidance for companies having their own program in place for verifying that wood comes from non-controversial sources. In the following, we provide an overview of these guidelines.
Major issues that will result in suspension
The advice note mentions several cases where noncompliance shall result in an immediate suspension of handling of controlled wood as a part of the certificate:
- Use of controlled wood for certified products without a risk assessment approved by the certifier; the risk assessment may be missing, incomplete or not approved.
- Absence of a publicly available written policy commitment in accordance with the standard.
- Absence of a complaint mechanism.
- Absence of supplier audit in districts with “unspecified risk”.
- Accepting controlled wood not originating directly from the forest (e.g. from terminals, primary manufactures, traders) without supplier audits to verify that the wood is not mixed with any non-controlled wood.
- Absence of sufficient documentation to demonstrate the district of origin for each supply. A declaration from the supplier is not sufficient.
It is also crucial that existing certified companies get approval for their risk assessment if they start sourcing from new areas. This can be done by sending it to the certifier, who will check it and publish it at the FSC homepage. Onsite visits will usually be required in case the company starts sourcing from “unspecified risk” areas for the first time.
The easy option - buy controlled wood from FSC suppliers
It is important to stress that the points above are only relevant for companies implementing their own verification program. Companies buying FSC Controlled Wood from FSC certified suppliers only need to verify that the supplier’s certificate is valid, that controlled wood is included in the scope and that the sales documents state “FSC Controlled Wood” and the supplier’s controlled wood certification code (e.g. SW-CW-123456).
Companies certified to deliver FSC Controlled Wood can be found on www.fsc-info.org and will have a green checkmark in the CW column. Currently about 270 companies are approved to sell “FSC Controlled Wood”, and the number is growing fast.
Risk Assessments on www.fsc-info.org
Certified companies have been required to make the risk assessment available for the public, but in reality it has been difficult to access them. FSC now requires risk assessments to be published in English (or Spanish) at the FSC certificate database (www.fsc-info.org). This will make it easier to gain an overview of all the risk evaluations done within a region or country.
For new FSC controlled wood certified companies, the risk assessments shall be published within 7 days after issuing the CW certificate code, while those of already certified companies shall be published before 13th of July 2008. The certification organisation is responsible for publishing the risk assessment. NEPCon is currently in the process of going through our clients’ risk assessments and translating them into English for publication.
Transparency International’s corruption index critical for legality verification
The FSC Controlled Wood standard identifies the Corruption Perception Index (CPI) issued by Transparency International as the key instrument for determining risk of illegal logging. The advice specifies that only countries with a CPI level at 5 or more can be classified as low risk. NEPCon provided guidance on the use of the CPI to our clients already back in October 2007 – see our article on this topic.
The certifier’s obligations
The advice note specifies that certification bodies shall visit any points where there is a risk of mixing controlled and non-controlled wood on the road from the forest to the certified company. For example, if a sawmill is buying round wood from a supplier’s terminal, the sawmill needs to ensure that the supplier has a system in place to separate controlled wood from non-controlled wood; and this has to be verified during an on-site visit conducted by the certifier. In case such a supplier is selling to several certified companies, it will reduce the overall costs if the supplier gets his own FSC Controlled Wood certificate.
Clear rules are set out for the level of field auditing by the certifier in case a company is sourcing from areas with “unspecified risk”. In such cases, the certifier shall visit 0.8 multiplied by the square root of the number of the field audits the company has to carry out. If a company is sourcing from e.g. 100 different forest operations during one year, the company will have to carry out field audits of at least 8 forest operations and the certifier shall perform field audits of 3 forest operations.