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FSC Standards Interpretations


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

FSC-STD-40-004 COC Certification


Question

Is it possible to downgrade an FSC output Claim?

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 6.1.1 g
Published Wednesday, 29. May 2013
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 invoice claim.

NOTE: FSC Mix % and FSC Recycled % output claims may be downgraded to claims with a lower percentage. The downgrading of FSC Recycled Credit output claims is not allowed.


Question

Is the FSC Mix 100% claim allowed?

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 6.1.1
Published Tuesday, 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.


Question

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

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 7.3.1
Published Tuesday, 23. April 2013
Answer

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


Question

Can a product that the supplier simultaneously invoiced as FSC and PEFC be considered as FSC certified input by the buyer?

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 4.1
Published Tuesday, 07. August 2012
Answer

Yes. However, in the case the buyer is also FSC and PEFC certified, the buyer shall provide its FSC Certification Body access to both FSC and PEFC production and certification controls (e.g. access to both FSC and PEFC 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 PEFC certification.


Question

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

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 9
Published Thursday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) 6.1.1, sub-clause f
Published Monday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) 6.2.1 and Scope
Published Monday, 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.


Question

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

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) 3.1.2
Published Monday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 2.1.3
Published Monday, 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.


Question

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

Normative Reference FSC-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
Published Monday, 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.


Question

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

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 6.1.1
Published Monday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 6.1.1
Published Friday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 2.1.2.b
Published Friday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Section 12
Published Friday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 6.1.3 and Section 13
Published Monday, 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.


Question

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

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 13.1.2 a)
Published Tuesday, 01. February 2011
Answer

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


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 12.1.1
Published Tuesday, 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.


Question

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

Normative Reference FSC-STD-40-004 V2-1
Requirement(s) N/A
Published Tuesday, 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.


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 Reference FSC-STD-40-004 V2-1
Requirement(s) Clause 12.1.1 a)
Published Tuesday, 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.