FSC rules for minor components – reality check

6 December 2007

The last draft of the FSC Chain of Custody standard circulated for public consultation implied that FSC certified assembled products could contain up to 5 per cent of so-called minor components made of non-certified material -provided that it was not surface veneer or products made from CITES species.

The concept was designed to help producers of assembled products such as furniture. For such products, it is a special problem to get all minor components such as dowels, handles or maybe the back cover of a cupboard as FSC certified, or even to document that the component does not originate from controversial sources. Such components are in many cases bought from local non-certified retailers who are not allowed to sell them as FSC certified or as FSC controlled wood certified on sales documents.

The 5% threshold is still included in the final FSC-endorsed version of the standard. But it also sets out a new requirement not contained in any of the drafts put out for public consultation: if the volume of minor components is between 1% and 5 % of the total volume, the producer now needs to apply to the FSC for derogation. And here the problems start.

THE DEROGATION PROCEDURE

Imagine a carpenter or smaller furniture manufacturer producing furniture according to costumer-designed orders. If the manufacturer receives a request for a specific FSC certified model, and his calculations show that only 97% of the volume can be made of FSC certified raw material, then he has to go through the following procedure:

1. Prepare a market analysis documenting that the remaining 3% of the wooden components are not available as FSC certified or as FSC controlled wood certified.
2. Elaborate an action plan for how the 3 % can be reduced for future production.
3. Fill in an application form for derogation.
4. Translate the application into English.
5. Ask his certifier to review the application and ensure that all required information is included.
6. The certifier shall forward the derogation application to FSC.
7. Within 4 weeks the FSC must approve or disapprove the application, or request more time.
8. In case of approval, the certifier has to inform the manufacturer.

The customer needs to be rather patient, considering that it will probably take several months before the manufacturer knows if he can sell the products as FSC certified. In addition, the procedure will increase the cost of manufacturing a certified product. We expect that both the certifier and the FSC will charge a fee for handling the derogations.

While the 5% rule for minor components was introduced to help small-scale manufacturers, this group ironically seems likely to be the loser of the game. The derogation procedures are most probably too costly, too time-consuming and too complicated to work for them.

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