FSC has published several adjustments within its forest management, chain of custody and controlled wood systems. The changes effectively weed out nearly all remaining inconsistencies with the EUTR, the Lacey Act and the Australian Illegal Logging Prohibition Act.
”I commend FSC for its strong and targeted effort to put all its paperwork in place in conjunction with the enforcement of the EU Timber Regulation on 3 March 2013”, comments Forest Legality Programme Manager at NEPCon Christian Sloth.
”FSC has effectively sealed remaining gaps, such as inclusion of customs and trade laws as part of its legality assurance systems”.
Only one area is yet to be revised to ensure 100 % alignment of FSC’s entire system of mandatory standards and guidance. This concerns the definition of reclaimed material in the EUTR and the FSC systems, respectively.
The EUTR exempts recycled material from the due diligence requirements and defines recycled material as “timber and timber products that have completed their lifecycle, and would otherwise be disposed of as waste”, whereas FSC allows both pre- and post-consumer recycled material to become FSC certified as reclaimed material. There is a potential discrepancy between the definitions used by the EU and FSC, and FSC is currently addressing this.
FSC set to play a leading role in EUTR risk mitigation
Products already on the market have been produced under the previous set of requirements, and in some cases a period of time is allowed for existing certificate holders to adjust their systems to the new requirements.
”We will not see 100 % alignment covering all FSC certified products overnight, but FSC has now secured the framework that will bring FSC to full alignment. That is a major milestone achieved by a scheme with thousands of users globally", says Mr Sloth.
"However, FSC certification is already now among the best options available for mitigating risk of sourcing illegal timber. And with the latest revisions and the general expansion of FSC certification worldwide, FSC is set to continue playing a leading role in providing legality assurance under the new legal frameworks”.
Key changes
FSC has amended the documents listed below. The key highlights are:
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The definition of timber legality is now fully in line with the broad definition applied by EU: FSC has effectively incorporated the new definition into its forest management, chain of custody and controlled wood systems. Among other changes, FSC chain of custody certificate holders exporting and/or importing timber or timber products are now obliged to have procedures in place to ensure that the commercialisation of FSC certified products comply with all applicable trade and custom laws.
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Minor components phase-out will happen faster: FSC has secured alignment not only with the EUTR but also with the US Lacey Act and the Australian Illegal Logging Prohibition Act, by requiring certificate holders operating on specific markets to comply with legality frameworks in place on those markets. More importantly, the deadline has been moved forward. After 31 December 2013 and applying worldwide, the production of FSC products containing uncertified and uncontrolled minor components is no longer allowed.
FSC documents amended for EUTR alignment – an overview
Below is a concise overview of the formal documents which have been revised in conjunction with FSC’s alignment process. More comprehensive information about changes in specific requirements and related deadlines for compliance will be described in the next issue of Certified Wood Update.
FSC directives include FSC advice notes providing explanation and interpretation of the chain of custody requirements. FSC advice notes are mandatory for FSC certificate holders to follow.
The FSC Chain of Custody Directive (FSC-DIR-40-004). Includes amended versions of three existing advice notes non-conforming products (ADV-40-004-08), minor components (ADV-40-004-09) and access to information (ADV-40-004-10) as well as a new advice note on trade and customs laws (ADV-40-004-11).
FSC advice note on Applicable National Legislation (FSC-ADV-30-010) |
Aligns the list of applicable legislation to be met by Controlled wood certified forest operations with the EUTR. |
FSC directive on company evaluation of Controlled Wood (FSC-DIR-40-005) |
Incorporates the revised list of applicable legislation into the FSC requirements for company evaluation of Controlled Wood. |
FSC directive on Forest Management evaluations (FSC-DIR-20-007) | Incorporates the revised list of applicable legislation into FSC Forest Management certification processes. |