Interpretations of the normative framework


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


FSC-STD-20-001 Accreditation


Question

Can an FM/CoC Certificate Holder sell certified material as FSC Controlled Wood?

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)FSC-STD-20-001 V3-0
PublishedFriday, 21. November 2014

Answer

Yes. The FM-CoC Certificate Holder may opt to sell FSC certified material as FSC Controlled Wood by downgrading the output claim*, subject to the following conditions:

- The Certificate Holder shall conform to all applicable requirements for FSC Controlled Wood claims provided in FSC-STD-50-001 and Annex 3 of the standard FSC-STD-30-010;

- The Certification Body shall issue an additional certificate code of the form: XXX-FM/CW-######-ABC, where XXX are the initials of the certification body agreed with FSC, ###### is a unique six digit number or combination of numbers and letters issued by the Certifica-tion Body itself, and ABC is a sub-certificate code issued only to the members of group certificates, in the form, A, B, C, AA, AB, etc.).

For reasons of clarity the Certification Body shall not use the same code number for valid certificates issued to different legal entities (i.e., the Certification Body would not issue a CoC certificate XXX-COC-123456 to company A, and an FM certificate XXX-FM-123456 to company B).

If a certificate is withdrawn and later re-issued to the same legal entity, the original registra-tion code may be used.

- The FM certificate code shall be used for the identification of the certificate. The FM/CW code shall be included along with the FM certificate code in the certification reports pre-pared according to the standard FSC-STD-20-007a and in the public summary reports prepared according to the standard FSC-STD-20-007b.

- The FM/CW code shall be used to make FSC Controlled Wood claims on invoices.


* Please see the Standard Interpretation of the standard FSC-FSC-40-004 from 29 May 2013 on downgrading claims for Chain of Custody certification.

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Question

A certificate holder having a single FMU in the scope of certification has applied for a change of the scope to add a significant new area to the FMU.
If major non-conformities (NCs) are identified in the area to be added during the change of scope audit or the surveillance audit prior to the decision, is their correction a precondition to grant the change of scope?

Normative ReferenceFSC-STD-20-001
Requirement(s)7.5
PublishedTuesday, 07. October 2014

Answer

Yes, if the major non-conformity is linked to the area to be added.
If the major non-conformity is independent of the area to be added, but linked to the overall management system, the area can be added to the certificate before the non-conformity is closed.

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Question

Is it possible to split an existing FSC Forest Management certificate into two separate certificates, following a surveillance evaluation?

Normative ReferenceFSC-STD-20-001
Requirement(s)7.5
PublishedMonday, 06. October 2014

Answer

Yes, provided that in the surveillance evaluation this change of the scope was evaluated according to FSC-STD-20-001 Clause 7.5.
If the change of the scope was not evaluated in the surveillance evaluation, another evaluation according to the requirements above will be required.

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Question

How is the certification body expected to control the FSC trademark use of their clients following its approval?

Normative ReferenceFSC-STD-20-001
Requirement(s)Clause 21.2
PublishedMonday, 19. May 2014

Answer

The certification body is expected to control the FSC trademark use by:
- auditing the trademark use at minimum at the time of the annual surveillance evaluations and re-evaluations (sampling can be applied); and
- addressing cases of detected or reported trademark misuses by their clients.

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Question

Is it considered a conflict of interest if an FSC accredited certification body is formally recognised as a Monitoring Organisation according to the EU Timber Regulation (# 995/2010) and in this function monitors its FSC certified clients?

Normative ReferenceFSC-STD-20-001
Requirement(s)Clause 3.1; Annex 1
PublishedMonday, 19. May 2014

Answer

No, FSC does not consider it a conflict of interest, if an FSC accredited certification body is also servicing their FSC certified clients as Monitoring Organisation in the context of the EUTR, as this service does not cover compliance elements of the FSC standards.

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Question

How shall university education or ‘equivalent’ be interpreted according to the requirements for auditor qualification provided in the standard FSC-STD-20-001?

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)1.3, 1.5
PublishedFriday, 11. April 2014

Answer

University level education is equal to higher education (tertiary or third level education) in a discipline relevant to the evaluation (e.g. ecology, forestry, sociology, economics, anthropology).
An equivalent of university education may be secondary education, and a minimum of 10 years of professional experience in an area of work relevant to forestry evaluation (e.g. forest management, postgraduate research, consultancy).

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Question

Shall CB auditors and CB audit teams conducting Controlled Wood evaluations at FMU level (according to FSC-STD-40-005, Annex 3) have the same qualification as for evaluations of Forest Management Enterprises (according to FSC-STD-30-010)?

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)Annex 2, Clause 1.5; Annex 3, Section 3
PublishedWednesday, 05. February 2014

Answer

Yes, CB auditors conducting Controlled Wood evaluations at FMU level shall comply with auditor qualifications specified in FSC-STD-20-001, Annex 2, Clause 1.5
Audit teams shall comply with qualifications as specified in FSC-STD-20-001, Annex 3, Section 3.

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Question

Can a 3-days ISO 19011 training course (incl. exam) be accepted as qualification for lead auditors after 31 December 2012?

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)Annex 2, Clause 1.2
PublishedFriday, 15. November 2013

Answer

Yes, the transitional exception for lead auditor training (FSC-STD-20-001 V3-0, Annex 2, Clause 1.2) has been extended until the next revision of FSC-STD-20-001 (scheduled for 2013/14).

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Question

Is it required to assess the Certificate Holder (CH) within the next 12 months from the last surveillance audit?

Normative ReferenceFSC-STD-20-001
Requirement(s)Clause 20.1
PublishedWednesday, 11. September 2013

Answer

Not for surveillance evaluations. FSC-STD-20-001 Clause 20.1 states that surveillance evaluations of FSC CHs shall take place at least annually and a PSU interpretation states that in the context of surveillance “annually” is to be interpreted as follows:

  • FM audits: at least once per calendar year (to allow flexibility for evaluating seasonal activities);
  • COC audits: at least once per calendar year, but it should not be later than 15 months after the last audit.
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Question

FSC-STD-20-001 requires that a chain of custody evaluation team shall always include at least one team member who is fluent in the language of the area in which the evaluation takes place, or a designated independent interpreter. Are there any scenarios that could warrant an exception to this rule, such as cases where the parent company has a standard corporate language requirement which is different from the local language?

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)Annex 3, Clause 2.1.2
PublishedWednesday, 29. May 2013

Answer

It is acceptable that the evaluation team include at least one team member who is fluent in the corporate language instead of the local language if all of the following criteria are met:

  • All relevant records and procedures for the CoC system are written and understood in the corporate language;
  • All management staff and those with FSC responsibilities can communicate fluently in the corporate language.
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Question

Can an ASI witness audit be substituted for a witness audit carried out by the CB to meet the requirements of 12.4? In other words does a witness audit performed by ASI on a particular Lead audit fulfill this requirement or are CBs required to conduct a witness audit of every lead audit regardless of whether or not they have been witnessed by ASI to conform to this requirement?

Normative ReferenceFSC-STD-20-001
Requirement(s)12.4
PublishedTuesday, 28. May 2013

Answer

No, the responsibility for complying with the requirements of FSC-STD-20-001 cannot be “outsourced” to ASI.

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Question

Is it possible to issue certificates to non-registered entities?
Are the following examples possible?

Certificate issued to "FMU ABC" or "Certification Group XYZ" (not necessarily a legal entity) represented by Forest Management Enterprise Ltd. (legal entity) Woodstreet 1, 12345 Greenhills. Timberland

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)Clause 19.6; Clause 7.2.
PublishedFriday, 07. September 2012

Answer

No, it is not possible to issue certificates to unregistered entities. Certificates shall be issued to legal entities.

According to Clause 19.6 c) in FSC-STD-20-001 V3-0, all FM and COC certificates shall include (…) the legal name and registered address of the certificate holder, plus any trade names and other addresses that will be used for sales invoices.

Furthermore, according to Clause 7.2.a) of the same standard, a client needs to have entered into and hold a valid TLA ‘License Agreement for the FSC Certification Scheme’, which is not suspended. Only a legal entity can validly enter into a License Agreement.

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Question

A Resource Manager, located in Country A, manages forestlands in Country B (type II group scheme). All forestlands are owned by foreign investors with permanent addresses in Country A. No permanent address exists in Country B. Certificate holder is the forestmanager as resource manager.

Problem: The FSC Database only allows including one country. Hence, there is confusion about the “allocation of the FM certificate and certified area”.

Normative ReferenceFSC-STD-20-001, V3-0
Requirement(s)Clause 19.5 and 19.6
PublishedTuesday, 22. May 2012

Answer

Additional Information on the FMUs (such as location, etc) should be presented in the optional field “FMU comment” of the database.

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Question

Which documents are required to be uploaded to the FSC Database?

Normative Referencesee above
Requirement(s)see above
PublishedThursday, 22. March 2012

Answer

Certification Bodies are required to upload the following documents to the FSC Database:

  • Public summary reports of Forest Management certificates (FSC-STD-20-001 V3-0 Clause 19.5; FSC-STD-20-007b V1-0 Clause 3.1, 3.2;
  • Publicly available results of companies' Controlled Wood risk assessments (ADVICE-40-005-007 of FSC-DIR-40-005);
  • Form for registration and approval of FSC product groups grandfathered with the reduced labelling threshold percentage and exemption of Controlled Wood requirements for co-products (Annex A of FSC-DIR-40-004);
  • Application and evaluation form for minor components derogations (Annex 1 of FSC-PRO-40-004 V2-2);
  • FSC Trademark License Agreement (TLA)
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Question

Please clarify the definition of “annually”.

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)Clause 20.1.
PublishedTuesday, 01. March 2011

Answer

PSU interpretation (mandatory): In the context of surveillance “annually” is to be interpreted as follows:

  • FM audits: at least once per calendar year (to allow flexibility for evaluating seasonal activities);
  • COC audits: at least once per calendar year, but it should not be later than 15 months after the last audit.
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Question

What is meant by “relevant” customers?

Normative ReferenceFSC-STD-20-001 V3-0
Requirement(s)Clause 7.7b
PublishedMonday, 21. February 2011

Answer

The following customers are considered “relevant”:
Certified and uncertified clients who:

  • Bought certified material;
  • Placed an order or submitted an enquiry for certified products;
  • Otherwise expressed an interest in purchasing certified products.
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