Interpretations of the normative framework


This section gives you access to current standard interpretations separated by topics and related normative documents.


FSC-STD-40-004 COC Certification


Question

Are CBs required to verify how the CoC-CH demonstrated its commitment under the Policy for Association to not be involved in illegal logging?

Normative ReferenceFSC-STD-40-004 V2-1; FSC-STD-20-011 V2-0; FSC-PRO-20-001 V1-1
Requirement(s)Clause 1.5 of FSC-STD-40-004 V2-1; Clause 2.7d of FSC-STD-20-011 V2-0; Section 1 and 3 of FSC-PRO-20-001 V1-1
PublishedThursday, 11. February 2016

Answer

CBs have to verify (audit) the CH’s commitment to comply with the values of FSC as defined in the Policy for Association according to FSC-STD-40-004 V2-1 Clause 1.5.1. This needs to be done by evaluating the existence of the self-declaration signed by the CH (FSC-PRO-20-001 V1-1 Section 3). 

This is sufficient unless the CB witnesses objective evidence of non-conformance in the audit (FSC-PRO-20-001 V1-1 Section 1) or detects objective evidence of non-conformance when reviewing (evaluating) complaints, disputes or allegations of non-conformance received from stakeholders (FSC-STD-20-011-V2-0 Clause 2.7.d). This applies to any of the listed activities (see FSC-STD-40-004 V2-1 Clause 1.5.2), including illegal logging.

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Question

Does the requirement to review complaints, disputes or allegations of non-conformities received by the organization and/or the certification body entail an investigation of allegations made relating to issues which are not covered by FSC certification standards for certificate holders? Is the Policy for Association considered a “relevant standard” in the ISO 65 Clause 15?

As per FSC-STD-20-011 V2-0 Clause 2.7.d, what is involved in the “review of complaints, disputes, or allegations of non-conformities received” which the certification body is required to carry out?

1) Does the “review” as per FSC-STD-20-011-V2-0, 2.7(d), include a requirement that a CB investigates allegations made relating to the Policy for Association? 

2) Should the certification body investigate allegations made relating to deficiencies in products (e.g. poor quality product, albeit certified)? 

3) Is the CB required to perform independent verification of allegations by making contact with stakeholders who have submitted the allegations? 

4) In the case of a Policy for Association related allegation, is a CB required to evaluate the CHs actions with respect to the allegations?

Normative ReferenceISO Guide 65:1996; FSC-STD-20-001 V3-0; FSC-STD-20-011 V2-0; FSC-STD-40-004 V2-1
Requirement(s)Clause 7 and 15 of ISO Guide 65:1996; Clause 14 of FSC-STD-20-001 V3-0; Clause 2.7.d of FSC-STD-20-011 V2-0; Clause 1.5 of FSC-STD-40-004 V2-1
PublishedThursday, 11. February 2016

Answer

Complaints, disputes or allegations of non-conformance received from stakeholders by the certification body have to be reviewed in all cases according to FSC-STD-20-011 V2-0 Clause 2.7.d. They do however not have to be further evaluated if they are not within the scope of relevant FSC certification requirements (otherwise they would not classify as an ‘allegation of non-conformity’ by definition).
Complaints received by the CH have to be reviewed in all cases according to ISO 65 Clause 15. If they relate to compliance with relevant certification requirements, appropriate action must be taken by the CH and documented.

FSC-STD-40-004 V2-1 is the relevant standard for chain of custody certification in the context of ISO 65 Clause 15, including the requirements listed in Clause 1.5. Allegations of non-conformance against Clause 1.5 therefore need to be reviewed for any objective evidence. Such objective evidence for relevant non-conformities, even if provided only for operations or activities outside the scope of chain of custody certification, needs to be evaluated for indications of similar non-conformities within the scope of the certificate.

Regarding FSC-STD-20-011 V2-0 Clause 2.7.d:

#1: Yes, in so far that objective evidence of non-conformance in certain entities or parts of an associated organization could imply or indicate non-conformities in or even a breakdown of a certificate holder’s chain of custody or overall quality management system.

#2: The CB does not need to investigate allegations related to deficiencies in products (e.g. poor quality product). The CB needs to review allegations against CHs non-conformities against certification requirements. 
 
#3: FSC-STD-20-001 V3-0 Clause 14 in combination with ISO 65 Clause 7 requires CBs to give stakeholders the opportunity to present their case to the entity reviewing the allegation. FSC therefore considers it best practice to make contact with these stakeholders when reviewing and evaluating an allegation.

#4: ISO 65 Clause 15 requires the CB to evaluate the CH action with respect to all allegations that relate to compliance with relevant certification standards. Action taken with regards to allegations against the commitment of the CH with the Values of FSC as defined in the Policy for Association have to be investigated by the CB as they are included in a relevant certification standard, i.e. FSC-STD-40-004 V2-1 Clause 1.5.

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Question

Are certified retailers buying and selling finished and labelled FSC products allowed to downgrade output claims?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)6.2.1
PublishedMonday, 14. December 2015

Answer

Yes, retailers may do so. In such cases it is acceptable that the FSC claims on sales and delivery documentation do not correspond to the FSC claims on the labelled products. 

NOTE: This approach aims to facilitate application of the standard to retailers selling finished and labelled products to end-consumers that often only receive standardized receipts at the cash point. Clause 6.2.1 was not developed for organizations directly selling to end consumers.

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Question

Can a product that is invoiced simultaneously containing FSC claims and claims of another forestry certification scheme (such as PEFC or SFI) be considered as FSC certified input by the buyer?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 4.1
PublishedMonday, 05. October 2015

Answer

Yes. However, in the case the buyer is certified against FSC and another forestry certification scheme, the buyer shall provide its FSC Certification Body access to both production and certification controls (access to both FSC and e.g. PEFC or SFI credit accounts) for verification that the volumes received are not being double counted. This requirement also applies in cases where the FSC accredited Certification Body is not accredited for certification against the other forestry certification scheme.

Amended on 05.10.2015; First published on 06.08.2012 

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Question

Are organizations required to keep records of supplier delivery documents (where available)?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 1.4.2
PublishedFriday, 24. July 2015

Answer

Organizations need to keep sales documents as key records (documents showing the transfer of ownership). Where available, these shall be the invoices. It is not required to keep multiple sales documents of the same transaction. Legal obligations for record keeping remain unaffected.

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Question

Is an organization allowed to include the FSC Chain of Custody code of its supplier on the invoice, in addition to its own code?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 6.1.1
PublishedFriday, 24. July 2015

Answer

Yes, but it must be clear which code belongs to the organization issuing the invoice and which is the suppliers’ code.

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Question

Can a COC certificate holder establish a product group list that includes products that are not eligible to be sold with an FSC claim?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 2.1.1
PublishedFriday, 24. July 2015

Answer

No, Clause 2.1.1 of FSC-STD-40-004 V2-1 specifies that organizations shall establish product groups for the products that will be sold with FSC claims. Therefore, FSC product groups shall only include products that are eligible to be sold with FSC claims.

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Question

Is it possible to downgrade an FSC output claim?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 6.1.1.g
PublishedFriday, 24. July 2015

Answer

Yes, the following FSC output claims may be downgraded in any of the three systems for controlling FSC Claims (Transfer, Percentage and Credit System) as presented in the diagram attached. In all cases, the FSC label shall correspond to the FSC claim made on sales documents.
NOTE: FSC Recycled products cannot be downgraded to FSC Controlled Wood since they do not meet FSC Controlled Wood requirements.

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Question

Do FSC claims need to be spelled in sales documents as they are spelled in the COC standard FSC-STD-40-004?

Normative ReferenceFSC-STD-40-004
Requirement(s)Definition FSC claim
PublishedWednesday, 10. June 2015

Answer

The standard is not prescriptive about how the FSC claims should be spelled in sales documents. Therefore, only the 'FSC' acronym needs to be written in capital letters in FSC claims. The certified content specification (e.g. 100%, Mix Credit, Recycled 85%) may be spelled in lower case and/ or upper case (e.g. both FSC Mix Credit and FSC MIX CREDIT).

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Question

Is it allowed to classify wood-based resin adhesives and lignin sulfonate used for sizing in paper production as “neutral”?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Scope
PublishedFriday, 13. February 2015

Answer

Yes, until FSC has developed an approach to verify this type of NTFP material it is acceptable to classify such material as “neutral”. 

NOTE: “Neutral” means that this material is exempt from Chain of Custody control requirements.

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Question

Where non-certified organizations that are not required to be certified are involved in issuing sales or delivery documents (e.g. transporting companies, sub-contractors, 'del credere' agents), is it acceptable that only the invoice or the delivery document is used to identify inputs and outputs sold with FSC claims?

Normative ReferenceFSC-STD-40-004
Requirement(s)Clauses 4.1.1; 6.1.1; 6.1.2
PublishedMonday, 19. May 2014

Answer

Yes, non-certified organizations shall not use the certification code of certified organizations in their own documents. In these exceptional cases it is sufficient that only the sales or delivery document issued by the certified organization contains all information as specified in Clause 6.1.1 and is used to identify inputs and outputs sold with FSC claims. The document issued by the non-certified organization shall contain sufficient information to link the sale and related delivery documentation to each other.

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Question

Are certified or non-certified subcontractors allowed to include the certificate code of the contracting certified organization in their own sales and delivery documentation?

Normative ReferenceFSC-STD-40-004
Requirement(s)Clause 6.1.1
PublishedMonday, 19. May 2014

Answer

No, organizations can only use their own certificate code in their sales and delivery documentation, not the certificate code of another certified organization.

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Question

Is the FSC Mix 100% claim allowed?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 6.1.1
PublishedTuesday, 23. April 2013

Answer

Yes, the FSC Mix 100% claim is allowed on sales and delivery documents only. Although the FSC Mix 100% claim is accepted it is recommended to use the FSC Mix Credit claim instead. For labelling of these products, the FSC Mix label shall be used.

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Question

Which output claim shall be used when inputs with different FSC claims are combined in the Transfer System?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 7.3.1
PublishedTuesday, 23. April 2013

Answer

The attached table presents the possible combinations of FSC input claims and resulting output claims when applying the Transfer System.

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Question

Are traders authorized to apply the credit system for trading of unfinished products?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 9
PublishedThursday, 01. December 2011

Answer

Traders can apply the credit system on the level of a trading office site under the following conditions:
1) For the trade of primary products (e.g. logs, chips), and
2) Exclusive for domestic trading (at national level), and
3) There shall be a recognized third party measuring and control system of the forest products in place in order to ensure compliance with FSC product group definition (especially Clause 2.1.3), and
4) The trade of FSC certified products is always linked to a physical delivery of products. Virtual transfers of certified products are prohibited.

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Question

In some countries, self-billing Invoices (SBIs) prepared by the purchaser are a substitute document for an invoice by the seller. It is acceptable that the purchaser uses the certification code of the seller in SBIs?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)6.1.1, sub-clause f
PublishedMonday, 05. September 2011

Answer

Yes. As SBIs represent a long established business practice in the forestry industry and fully accepted by the tax authorities, it is acceptable that purchaser uses the certification code of the seller, or includes both the seller's and the purchaser's certification code in SBIs.

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Question

According to FSC-STD-40-004 V2-1, publishers and retailers are not required to be certified in order to resell FSC finished products, unless they perform at least one of the following activities:
a) Pass on the FSC Claim to subsequent customers through sales and delivery documents;
b) Apply the FSC label on-product;
c) Process or transform FSC certified products (e.g. manufacturing, repackaging, relabeling, adding other forest-based components to the product).
However, some companies that don’t need certification are FSC certified in order to demonstrate their commitment to the FSC certification principles and values. In this context, are certified publishers and retailers required to comply with Clause 6.2.1 of FSC-STD-40-004 V2-1 if they sell finished certified products to customers that don’t need or want to receive the invoices with FSC Claims on it?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)6.2.1 and Scope
PublishedMonday, 05. September 2011

Answer

No, for certified publishers and retailers that sell finished certified products to customers that don’t need or want to receive the invoices with FSC Claims on it, Clause 6.2.1 may be classified as not being applicable.

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Question

Is PEFC certified material eligible to be used in FSC product groups as FSC certified or FSC Controlled Wood?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)3.1.2
PublishedMonday, 15. August 2011

Answer

No. Material certified by the Program for Endorsement of Forest Certification (PEFC) is not accepted as FSC certified input and does not automatically meet the requirements of the FSC Controlled Wood standards. Therefore PEFC certified material classifies as non-FSC certified input and must comply with FSC Controlled Wood standards before its use in FSC product groups.

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Question

Is it acceptable to define credit system product groups by FSC claim and product type only, with no regard to input characteristics?
For example, a door manufacturer produces the following door types:
a) Solid wood door – sawn material components, dowels as minor components
b) Sandwich door Type 1 – sawn material components, veneer, skins, chip board
c) Sandwich door Type 2 – sawn material components, veneer, fiber board, chip board, honey comb
Could they define one product group (FSC Mixed Credit doors) and use one credit account for all of these door types?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 2.1.3
PublishedMonday, 18. April 2011

Answer

No, product groups under the credit system shall share similar input and output characteristics, in terms of quality and conversion factor, as defined in FSC-STD-40-004 Clause 2.1.3 and “Terms and Definitions”. The term “quality” represents characteristics in terms of species, composition/ specifications or value of the materials. It means that products that contain inputs of different quality (e.g. sawn wood and fiber board) and/or with different conversion factors (e.g. solid wood and sandwich door) cannot be combined in the same product group. Credits from materials of a certain quality (e.g. chip board) cannot be transferred to materials of different quality (e.g. veneer). Thus, the credit system is not applicable for the production of products composed by materials of different “qualities”, unless the organization establishes separate credit accounts for each input material.

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Question

Is it acceptable that the FSC Claims are abbreviated (e.g. FSC Mix Cred) due to space constraints in invoices?

Normative ReferenceFSC-STD-40-004 V2-1 and FSC-DIR-40-004
Requirement(s)Clause 6.1.1 of FSC-STD-40-004 V2-1 and ADVICE-40-004-05 of FSC-DIR-40-004
PublishedMonday, 18. April 2011

Answer

Yes, with the condition that:
a) The abbreviation of FSC Claims is clearly defined in the organization’s documented procedures, and
b) The complete FSC claim is provided to customers through supplementary evidence, as defined in ADVICE-40-004-05 of FSC-DIR-40-004.

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Question

In which language shall the FSC claims on sales and delivery documents be written?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 6.1.1
PublishedMonday, 18. April 2011

Answer

The FSC Claims on sales and delivery documents shall be written in English in the case of international sales. However, it is acceptable that the FSC Claim is translated to the other languages in the case of sales at national level (e.g. when both supplier and customer are located in the same country) or when the official language in the country of the supplier and customer is the same.

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Question

Is it acceptable that a product sold with a FSC claim also contains claims of other forestry conformity assessment schemes in its sales and delivery documents?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 6.1.1
PublishedFriday, 15. April 2011

Answer

Yes. The FSC Chain of Custody and Trademark standards only present restrictions for the use of the FSC label on products together with the label of other forestry conformity assessment schemes. However, these restrictions do not apply for the identification of sales and delivery documents. In this case, the FSC claims and claims of other certification schemes shall not be merged. All elements of the FSC claim must be comprehensible and easily identifiable.

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Question

Is it acceptable to switch between credit and percentage control systems in a product group? For example, an organization uses the percentage system, but when the end of the claim period comes, they have not obtained enough input volume to reach the labelling threshold of 70%. Then they switch to the credit system and sell a volume of FSC Mixed Credit material equal to the Mixed XX% calculation.

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 2.1.2.b
PublishedFriday, 15. April 2011

Answer

No, the organization cannot have two systems of control for the same product group and switch from one to another ad libitum. In a situation where the organization cannot reach the minimum threshold for labelling, the products can still be claimed as FSC certified on invoices informing the applicable FSC percentage (e.g. FSC Mixed 45%), but the FSC label shall not be applied.
However, an organization may decide to permanently switch from one control system to another by defining a new product group. In this case the following shall apply regarding remaining eligible material:
1. from the percentage to the credit system: the organization may enter in its credit account an input equivalent to the volume of FSC Mixed x% output resulting from the last claim period or job order that was not sold under the percentage system.
2. from credit to percentage system: the remaining credits from the credit account cannot be used as input for the percentage system.

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Question

Are FSC outsourcing requirements applicable in the following situation: A subcontractor runs a scaling operation (scale house), which is located on-site at the FSC certified company's property?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Section 12
PublishedFriday, 15. April 2011

Answer

No, outsourcing requirements are only applicable when the subcontractor takes physical possession of FSC certified material, off-site from a FSC certified organization. If a subcontracted activity occurs on-site at a FSC certified organization, then the activity shall be included in the certificate scope and evaluated as part of the organization's CoC audit.

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Question

Do companies that are buying certified products containing a minor component (i.e. where the minor component has already been incorporated into the product under the certificate of the supplier) also need to apply for a derogation?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 6.1.3 and Section 13
PublishedMonday, 14. February 2011

Answer

The customer shall apply for derogation in case the product:
a) will be used as input for the manufacturing of another FSC product, and
b) the minor component material will constitute between 1% and 5% of the volume or weight of the customer’s product.
In case the customer is just trading the product without any transformation, the derogation is not necessary, but the clause 6.1.3 of FSC-STD-40-004 applies.

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Question

Is FSC allowing edge-banding made from solid wood veneer to be considered a minor component?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 13.1.2 a)
PublishedTuesday, 01. February 2011

Answer

No, edge-banding made from solid wood veneer does not qualify as minor component.

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Question

A FSC pulp producer ships its finished bales of pulp to a warehouse where it sits awaiting loading into ships or rail cars. The company does not relinquish ownership and the product is not altered in any way from the time it leaves the company facility to the warehouse and then into the ship or train. Is the process of warehousing considered outsourcing?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 12.1.1
PublishedTuesday, 01. February 2011

Answer

Storage sites should be exempt from CoC evaluations where they constitute 'stopping places' or intersections only as part of transport agreements between two Chain of Custody operations. In other words, where certain storage facilities are used (or rented) by transport service providers to fulfill a contractual agreement between two CoC certified operations, such sites should not be considered part of an outsourcing agreement. Where, however, a CoC operation contracts a transport service provider or the warehouse owner to store goods in the absence of an agreed delivery to a customer (and would then only place a delivery order at a later point in time, once a sales contract has been signed), such a scenario should be considered an extension of the storage site of the CoC operation and justify to look at it as an outsourcing arrangement.

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Question

Can an industry use old coconut palm trees from plantations as recycled wood?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)N/A
PublishedTuesday, 01. February 2011

Answer

Coconut fibre is not considered as wood since it is a palm-derived material, despite of its similar commercial and functional properties compared to material from trees. This conclusion is based on the botanical definition that wood is an organic material produced by Dicots species and palms pertain to Monocots group of plants.
FSC considers this material as a non-timber forest product where it originates from forests and as non-forest based material where it originates otherwise. The certification of coconut fibre would be possible in case that the material is produced in a forest based system (native forest or plantations). Therefore, palms produced from other land use systems are not subject to FSC certification and their material can be included in FSC certified products as non-forest based material. Also, this material is not eligible to be certified as FSC Recycled, since FSC considers the use of this material as a primary use of the palm trunks and, to be post-consumer reclaimed, it should be necessarily reclaimed from consumers.

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Question

A printer outsources part of its production to a non-FSC certified contractor. Can the contractor buy FSC paper and add it to an outsourced production?

Normative ReferenceFSC-STD-40-004 V2-1
Requirement(s)Clause 12.1.1 a)
PublishedTuesday, 01. February 2011

Answer

No, non-certified outsourcing contractors cannot buy and add forest-based material on their own, as per definition the contracting organization would not have ownership of all input materials. This would be different for certified contractors where they both act as contractors as well as suppliers with a purchase function on their own.

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