CONFUSION ABOUT THE FSC CHAIN OF CUSTODY STANDARDS REACHES A NEW PEAK

7 November 2007

Are you wondering which FSC Chain of Custody rules are currently valid or which of the multitude of rules you should actually follow? Then you may find it worth while to explore this article.

GROWING COMPLEXITY

In a few days, FSC expects to approve yet another version of its Chain of Custody standard – FSC-STD-40-004 version 2.0. The already considerable confusion among certified companies is consequently going to reach another peak: No less than three very different versions of FSC Chain of Custody standards will be applicable simultaneously, and these can even be combined with additional standards for “Controlled Wood”, something called ”percentage-based claims” as well as three different sets of rules for using the FSC trademarks.

On top of that, FSC has issued a number of other standards, policies, advice notes and guidance documents regulating different aspects of Chain of Custody certification such as outsourcing, multi-site certification, group certification - just to mention a few of them.

We’re not surprised if you feel a bit lost by now. The days when the Chain of Custody rules were the easy part of the FSC system, with scarcely more than 2 pages of rules, seem to be gone for ever.

Not until 2009, when FSC phases out the older versions of the standards, the situation can be expected to clear up. By that time, all companies will have to follow the new versions. From 2009 onwards, we may expect a single standard for Chain of Custody, one for FSC Controlled Wood, and two standards for the use of the FSC trademarks (on-product and promotional use). That is, excluding the possibility that FSC should invent something new in the meantime!

WHAT YOU SHOULD DO

Please find below some answers to your key questions.

If you are preparing for certification, we recommend you to prepare your system based on the new CoC standards: version 2.0 of the FSC-STD-40-004. At this moment only a final draft is available, but the approved version is expected to be published within a few days. We don’t expect any major changes in the final version compared to the draft. If you plan to mix FSC certified material with non-FSC certified material, you need to add version 2.1 of the FSC-STD-40-005.

However, in case you plan the certification audit before 1st of January 2008, you may also choose to apply one of the older standards instead, but then you will have to update your system again to the new standard at the latest during the annual audit in 2009. This option should therefore only be chosen if you see some clear benefits in using the older standards.

If you are already certified, you can switch to the new FSC Chain of Custody standard as soon as it is approved, you have updated your system and it has been approved your certifier. Depending on the scale of changes in your system it may require an on-site audit by the certifier. If you can see any benefits in changing fast – then do it!

If not – then you can postpone switching to the new FSC Chain of Custody standard until your annual audit in 2009. This is the final deadline for your system to be fully updated and to start operating according to the version 2.0 of the standard.

However, if you are a producer of assembled products such as furniture, which include minor non-certified components such as dowels or coating paper which cannot be purchased as FSC Certified or FSC Controlled Wood – then the right time to switch is at your annual audit in 2008. The version 2.0 of the FSC Chain of Custody standard is expected to allow a minimal percent of non-certified material in certified products to help companies in situations like this. See also our article on the special problems faced by producers of assembled products.

AND WHAT ABOUT THE FSC CONTROLLED WOOD STANDARDS?

The FSC Controlled Wood standard FSC-STD-40-005 is for companies producing FSC certified products with a mix of FSC-certified and non-FSC certified material and for traders selling such material to FSC certified companies.

The version 2.1 of the standard is already applicable for all primary manufacturers and for traders of round wood. All companies manufacturing and trading round wood are expected to have changed to this new version of the standard by their 2007 audits.

All others (secondary manufactures, printers , traders assembling FSC-mixed collections, etc) shall change to the new standard during their annual audit in 2008. Therefore by the end of that year, all companies shall be operating according to the version 2.1 of the Controlled Wood standard.

MORE INFORMATION

The various standards are available on the FSC homepage.

The Rainforest Alliance has a developed a powerpoint presentation describing the rules.

In the December issue of “Certified Wood Update”, we expect to provide a detailed description of the new FSC Chain of custody standard (FSC-STD-40-004 ver 2.0).

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