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Producers of assembled products face trouble fulfilling new FSC requirements
7 November 2007
As from New Year, producers of FSC certified furniture, doors, windows, etc. will face a special challenge: Some assembled products containing non-certified parts cannot be sold as FSC certified any longer. This is the consequence of new controlled wood requirements which FSC introduces on the 1st of January.
Changes in requirements
According to the former rules, mixed FSC products could be sold as certified in case at least 70% of the solid wood was certified and the remainder came from “non-controversial sources”. In most cases manufacturers used a supplier declaration or a company policy as documentation for the non-controversial origin of the non-certified input. However, as pointed out mainly by environmental organisations, this system was not efficient to exclude controversial material from ending up in FSC certified products.
As a consequence, FSC is imposing much stricter requirements on the non-FSC certified components. They were first introduced this year for primary manufacturers such as sawmills and pulp mills. From New Year, the new FSC controlled wood standard (FSC-STD-40-005 ver 2.1) will be applicable all manufactures of mixed products.
With the new rules, it has to be verified that the non-FSC certified raw material is coming from non-controversial sources. As a basic step to ensure this, it must be possible to trace the wood back to its origin. But while primary manufacturers can easily control the sources and origin of the wood, this is often not possible for secondary manufacturers.
Primary manufacturers receive the wood directly from the forest and can control the origin. But for secondary manufacturers, the link to the forest is broken when wood from many different origins are mixed in the sawmill. And according to the new rules, a declaration from the supplier - stating where the wood comes from and confirming that it is not a controversial source - is no longer sufficient.
What are the options for these companies?
Companies producing mixed products therefore have to look for alternatives:
1. Use FSC certified wood only
One option is of course to replace non-certified components by FSC certified components, if that is possible. Some companies have been adding 30% non-certified material of the same nature to the product in order to increase the total volume of sold certified material; they may simply stop this practice and start producing 100% certified products. However, if details or components of a specific nature are needed and these are not available as certified, then the company is facing a problem..
2. Use “FSC Controlled Wood”
An increasing number of companies are getting certified in order to be able to provide material which has already been verified as non-controversial. This material can be purchased as “FSC Controlled Wood” and a controlled wood certification code needs to be applied to sales documents (e.g. SW-CW-123456). Unfortunately there is currently no publicly available list of companies certified to deliver “FSC Controlled Wood”, so it can be difficult to find the suppliers. However, today most FSC certified sawmills and pulp mills are able to deliver the non-certified part of their production as “FSC Controlled Wood”.
3. Minor components
For manufacturers using only a tiny share of non certified material in the products, we expect a solution in the new FSC Chain of Custody standard (FSC-STD-40-004 version 2.0), which should be published during the this month. According to the final draft of the standard, companies can use up to five per cent minor components as non-certified in case it is impossible to get them as certified or as controlled. This rule typically helps companies that cannot get minor components such as dowels or coating paper FSC certified, or a printing house having an uncertified insert in a magazine. Surface veneer and CITES species can not be used as minor components.
When shall the requirements be fulfilled?
The new FSC rules are valid from 1st of January 2008, and from this date the certifiers shall check these requirements during their audits. Companies must be ready to meet the new requirements from the date of their annual audit. So companies with the annual audit by the end of the year can relax for a few more months.
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