CONSULTATION ON THE STANDARD FSC-STD-40-005 REQUIREMENTS FOR SOURCING CONTROLLED WOOD (CLOSED)
Currently, in order to use material as Controlled Wood (CW), the FSC-certified Organization must implement Chain of Custody requirements (FSC-STD-40-004) and Controlled Wood requirements (FSC-STD-40-005). According to FSC-STD-40-005, the Organization shall only use material purchased as controlled from another FSC Certificate Holder or verify the material as controlled itself.
For CW verification completed by the Organization, the Organization must assess the region from where material is purchased via a Risk Assessment. When there is low threat of wood coming from any of the unacceptable sources, the risk designation for the region is low. Whenever there are potential risks in any of the Controlled Wood Categories or insufficient information to confirm low risk, risk designation is unspecified risk.
For unspecified risk regions, the Organization shall conduct further verification in accordance with FSC requirements. If the organization cannot demonstrate that the material meets the FSC requirements, it cannot be used in FSC Mix products nor sold with an FSC Controlled Wood claim.
As per Motion 51, company Risk Assessments will be phased out by 31 December 2014 and the National Risk Assessment will become the only source of risk determination for given areas. FSC consults new, robust requirements for NRAs.
New requirements for risk determination, as well as timber legality regulation requirements, are the main factors influencing the structure of the revised standard for CW evaluation by CoC-certified Organizations, FSC-STD-40-005 Requirements for Organizations’ evaluation of Controlled Wood.
Due to the low prowess of risk specification performed by Certificate Holders, revision of the requirements for risk determination has been recognized as of key importance for overall strengthening of the CW system. In the revised system, standard FSC-STD-40-005 is directly connected with National Risk Assessment(s) as the source of risk determination. Simultaneously, new requirements are aligned with timber regulation laws and require a due diligence system for chain of custody operations.
The main goal of the revised standard is to provide Organizations interested in CW certification with clear requirements for sufficient due diligence on how to evaluate Controlled Wood that originates from non-certified suppliers. These requirements are based on the risk determination of supply areas provided by National Risk Assessment(s).
Main changes and new elements
The main changes introduced by the revised standard FSC-STD-40-005 Requirements for Organizations’ evaluation of Controlled Wood are as follows:
- General requirements already covered by the superior standard FSC-STD-40-004 Standard for Chain of Custody Certification have been removed and will remain only in FSC-STD-40-004
- Scope of the Controlled Wood evaluation according to the FSC-STD-40-005 involves only evaluation from non FSC-certified suppliers and does not evaluate FSC Controlled Wood purchased already verified by another FSC-certified Organization and sold with an FSC-Controlled Wood invoice claim
- The directive FSC-DIR-40-005 is being eliminated and relevant requirements of the directive are incorporated in the presented draft FSC-STD-40-005, and
- Clear references to National Risk Assessments and control measures implementation prescribed for specified risk areas
Note on control measures implementation: requirements for control measures implementation, including e.g. field verification, expert engagement, stakeholder consultation etc. will be prescribed by the relevant National Risk Assessment(s) (NRA), thus any Organization applying for certification according to this standard shall follow relevant NRAs to meet all requirements for CW evaluation. In the current consulted draft of the standard FSC-STD-40-005, implementation of interim control measures is suggested to be allowed for a limited period of time; until NRA(s) are developed and approved. Organization will be required to conduct a comprehensive assessment base on assessment prescribed in the National risk Assessment Framework before material can be claimed as controlled.
- Proposed options of sourcing from areas not covered by the National Risk Assessment(s) (unassessed areas):
Option A: Sourcing only FSC-certified wood (according to the requirements of FSC-STD-30-010 or FSC-STD-01-001); and/or
Option B: Outsource forest supplies evaluation according to requirements of FSC-STD-30-010 to FSC-accredited certification bodies;
Option C: Follow the robust procedure similar to FSC-PRO-60-002b, the National Risk Assessment Framework, in order to apply interim Control measures prescribed in the standard FSC-STD-40-005.
Currently approved NRAs exist only for 14 countries*. Among ‘Top 20 countries’**, which contains the greatest number of company Risk Assessment that have been developed according to the current Annex 2 of the standard FSC-STD-40-005, only 4 countries are covered by National Risk Assessments (Russia, Poland, Spain (Iberian Peninsula) and Czech Republic).
Unspecified risk areas assessed in approved NRAs shall be treated as unassessed areas after revised Control Wood requirements are effective (target effective date is 1st January 2015). The adaptation period of existing NRAs to new requirements is currently under discussion.
For more information about NRA development see FSC website.
For more information on risk determination globally, please visit Global Forest Registry.
Given the importance of NRAs in the revised CW system the Technical Committee requested FSC to develop an NRA action plan to streamline NRA development and secure sufficient cover of risk determination throughout the world.
* Australia, Chile, Switzerland, UK, Portugal, Germany, Italy, Spain, Bulgaria, Czech Republic, Poland, Romania, Ukraine and Russia (in chronological order of approval).
** The list of ‘Top 20 countries’ in terms of the number of company developed Risk Assessments (from the highest to the lowest rank): USA, Canada, Latvia, Russia (NRA approved), Sweden, Estonia, France, Lithuania, Poland (NRA approved), Brazil, Spain (Iberian Peninsula, NRA approved), Finland, Austria, Czech Republic (NRA approved), Slovakia, Japan, Belgium, Ireland, India, South Africa.
- Trademark requirements for Controlled Wood will remain only in the Requirements for use of the FSC Trademarks by Certificate Holders standard (FSC-STD-50-001)
At this stage, several issues pertaining to requirements for Controlled Wood evaluation are still under discussion. As part of the consultation process, some of the issues have been formulated as notes or questions to stakeholders. The most important point is related to options for sourcing non-certified material from unassessed risk areas.
The proposed changes to the National Risk Assessment framework, along with standard FSC-STD-40-005 and the standard FSC-STD-30-010 constitute a major change in the current Controlled wood system, with significant impact on sourcing Controlled Wood both from areas covered and not covered by NRAs). Thus, stakeholders are strongly encouraged to provide feedback during public consultation on the applicable standards.
The main goal of this consultation is to seek stakeholders feedback in order to find solutions for sections which are still under discussion.
Feedback will be carefully analysed and incorporated in subsequent drafts of the Standard with the aim of meeting stakeholder expectations and further improvement of the proposed amendments.
Due to the importance of the Controlled Wood revision process and future implications of the introduced changes, FSC asks for strong stakeholder participation and highly welcomes your comments, question and suggestions. Simultaneously, we would strongly encourage Stakeholders to refer to the consulted NRA requirements and standard FSC-STD-30-010 when commenting on the proposed draft FSC-STD-40-005.
Please provide your comments using the attached comment form and send them to Joanna Nowakowska at firstname.lastname@example.org.
The deadline for submitting comments is 24th November 2013.