Revised FSC chain of custody standards out for public consultation

The final draft of the next version of the FSC’s chain of custody standard (FSC-STD-40-004) is now out for the last round of public consultation. The new standard is expected to become applicable for all companies applying for certification from the beginning of 2008, and will be fully enforced for all certificate holders from beginning of 2009. Now is your last chance to present your comments about the revised standard.

Compared to the standard currently in force, the new standard includes a number of changes. NEPCon’s chain of custody expert Hando Hain, who has participated in the FSC technical working group, considers the standard to be more clearly written than the last version.

”Various technical constraints were included in the first version due to lack of practical experience. These have been well addressed in the new standard. However, there is still room for improvement. Due to complicated requirements, issues regarding recycled contents remain difficult to understand. We in NEPCon would also like to see a more simple approach adopted in relation to the batch and claim periods in the standard.”, said Hain.

Overview of the changes

The most important changes in the new draft standard are:

The scope of the standard has been extended to cover all trading and manufacturing operations acting as part of the supply chain for forest products. This means that the standard also applies to printers, wholesalers and brokers.
The credit and threshold systems can not be used by traders of final products.
A new term “transfer system” has been adopted, under which a company can transfer any claim (FSC-pure, FSC-mixed with any percent; FSC-recycled etc.) of the input material to the final product as long as the material is kept physically separated. This used to be commonly known as a batch system, however in the new standard the scheme is more clearly described.
Until the end of 2009 the minimum thresholds for labeling remain 70% for solid wood and 50% for chip and fiber products. After 2009 all products, including chip and fiber products, have to have minimum 70% certified contents in order to be labeled as FSC certified.
The threshold system has been made more flexible, which means that if the minimum threshold for labeling is not reached, the company can choose to sell the material based on the credit system (e.g. if the content of certified material in a production is 69%, then 69% of the production can be sold as FSC-mixed 100% creditable).
Very small volumes of uncontrolled material can be included in assembled products, if it is justified and the company has an action plan for procuring these components as controlled or certified in future. In the present draft, the maximum allowed uncontrolled volume is 5%, however this is still being debated.
Post-consumer material (which includes up to 15% of pre-consumer material) can now be used as creditable; thus a mixture of post- and pre-consumer material containing not more than 15% of pre-consumer volume can be used to build up credit for selling FSC certified products.
Co-products shall no longer be exempt from FSC Controlled Wood requirements from the end of 2009
FSC claims for 'FSC Mixed' and 'FSC Recycled' products shall always be made with percentage information ranging up to 100% for material produced under the credit system.
In addition, there are changes in the structure and terminology of the standard.

You are welcome to contact Hando Hain at hh@nepcon.net if you have any specific questions or want to discuss the requirements of the new standards.

Your last chance to provide comments to the FSC

The deadline for providing comments on the new standard is 5th October 2007. If you wish to contribute comments to the FSC about the new standards, you should make sure to follow these guidelines:

Fill in this comment form with your specific comment
Fill in this contributor form with information about yourself
Send both forms to Stefan Salvador from the FSC at s.salvador@fsc.org
Only comments which follow these guidelines will be considered as formal comments by the FSC.

You can download all relevant materials below.

The draft version 2 of the FSC chain of custody standard (FSC-STD-40-004)

Overview on standard structure and document framework

Draft advice note: transitory requirements

Draft guidance: FSC product classification

Draft guidance: use of reclaimed materials

Compilation of comments on FSC-STD-40-004 Draft 2-0

The invitation for comments from the FSC