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Interpretations of the normative framework


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


FSC-STD-40-005 Evaluation of Controlled Wood


Question

ADVICE-40-005-09 indicates that “Companies will have a period of up to 12 months after the approval date to align their controlled wood verification programs to the approved risk designation by a National Initiative.” In many cases, this means a company risk assessment that designated low risk now needs to be aligned with a National Risk Assessment that designates unspecified risk. In these cases, does the certificate holder need to implement field verification according to Annex 3 of FSC-STD-40-005 V2-1 for areas of unspecified risk prior to the one-year transition date?

Normative ReferenceFSC-DIR-40-005
Requirement(s)ADVICE-40-005-09
PublishedMonday, 02. March 2015

Answer

Yes. When risk designations by an FSC Network Partner are approved, the certificate holder shall update its risk assessment to the outcomes of the NRA. Field verification according to Annex 3 of FSC-STD-40-005 V2-1 shall be implemented for areas of unspecified risk after the risk assessment is updated and shall be completed prior to the one-year transition date (12 months after the date of the approval of the NRA).

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Question

Shall the outcomes of a company verification program according to Annex 3 be made publicly available?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)Clause 13.2, Annex 3; ADVICE-40-005-07
PublishedTuesday, 28. October 2014

Answer

No, currently there are no requirements for publishing the outcomes of verification according to Annex 3. The standard does not limit such an opportunity, however.

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Question

If a company risk assessment or applicable National Risk Assessment concludes ‘unspecified risk’ for a district and then field verification at the forest level by a company implementing Annex 3 concludes ‘low risk’, is it possible to use the outcomes from the field verification as a source of information/evidence in the risk assessment to conclude low risk at the level of the whole district?

Normative ReferenceFSC-STD-40-005 V2-1
Requirement(s)FSC-STD-40-005 V2-1
PublishedTuesday, 28. October 2014

Answer

No, the field verification according to Annex 3 allows the verification of risk at the FMU level. The confirmation of low risk at the FMU level cannot be extrapolated to the district level.

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Question

If a certified company sources material that has previously been FSC certified or covered by another company’s FSC Controlled Wood verification program but has since been traded by a non-certified company (therefore breaking the Chain of Custody), can this material be considered controlled with-out conducting a full verification program and risk assessment?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005 (Advice 04)
Requirement(s)FSC-STD-40-005 V2-1; FSC-DIR-40-005 (Advice 04)
PublishedFriday, 10. October 2014

Answer

For previously FSC-certified material from a broken Chain of Custody to be considered as FSC Controlled Wood, the company must trace the material back to the certified company that traded it to the non-certified company where the Chain of Custody was broken, and con-duct an audit of the supply chain. This audit shall demonstrate with verifiable documentation that the material is identifiable and traceable and has not been mixed with uncontrolled material.

For previously controlled material from a broken Chain of Custody to be considered as FSC Controlled Wood, the district of origin must be determined within/though the company’s own Controlled Wood verification program, for which all relevant normative requirements apply. For this purpose, risk assessments performed by other entities (e.g. a supplier with a valid FSC certificate that includes FSC Controlled Wood in its scope that sold FSC Controlled Wood (without a claim) to a non-certified entity) may be used as additional sources of information.

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Question

Can timber of unknown origin collected from beaches be evaluated according to the standard FSC-STD-40-005?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, FSC-DIR-40-005
PublishedWednesday, 09. July 2014

Answer

No, timber collected from beaches is not eligible for evaluation under the FSC Controlled Wood Standard FSC-STD-40-005 V2-1.

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Question

Can a district of origin cover more than one country? If so, is a separate risk assessment required for each country, given the heterogeneity in assessing risk between two different sets of laws? What about within countries where the sub-national units (states, provinces, etc.) have the independence to create their own resource use and protection laws?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, FSC-DIR-40-005
PublishedWednesday, 09. July 2014

Answer

According to its definition, a ‘district’ is considered to be a generic geographical definition within a country. Subject to the above, various guidance and requirements are provided stating that how a district shall be established depends on the CW category under assessment. In the case of National Risk Assessments (NRAs) it is possible to develop shared NRAs for countries sharing homogenous conditions (e.g. sharing the same ecoregions), according to the procedure FSC-PRO-60-002 V2-0 (FSC Controlled Wood Risk Assessments by FSC accredited National Initiatives, National and Regional offices).

Subject to the specific conditions of each CW category, the division of a country into sub-national units (e.g. states, provinces) will only impact how a district is defined if those divisions result in increased heterogeneity of the level or type of risk that is assessed within them.

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Question

Is a CoC-certified harvesting company that DOES NOT own or manage the forest required to conduct a nature value assessment when conducting a risk assessment according to Annex 2 of FSC-STD-40-005, when a nature value assessment is required by the respective National Forest Stewardship Standard?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, FSC-DIR-40-005
PublishedWednesday, 09. July 2014

Answer

No, a company that is conducting a risk assessment according to Annex 2 of FSC-STD-40-005 (V2-1) is not required to perform a nature value assessment, unless it is required by an approved national guidance as per Annex 2, part A, Clause 2 of FSC-STD-40-005 and/or as per FSC-DIR-40-005-09, Clause 3 (Advice).

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Question

In cases where there is an approved national risk assessment, is it acceptable for the certificate holder to use the National Risk Assessment to satisfy the controlled wood requirements for conducting a risk assessment as specified in FSC-STD-40-005 and FSC-DIR-40-005, rather than having to generate its own risk assessment?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, Section 11; FSC-DIR-40-005-09
PublishedWednesday, 09. July 2014

Answer

The use of approved National Risk Assessments (NRAs) for sourcing Controlled Wood according to FSC-STD-40-005 is mandatory. Certificate holders have different options for aligning their verification programs with the results of applicable NRAs. Certificate holders may, for example, use NRAs available on FSC’s website and/or the Global Forest Registry, or generate or update a new or existing company-developed risk assessment with the risk designation(s) provided in relevant NRAs. These examples are not exhaustive.

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Question

Does the concept of ‘minimally disturbed by human economic activity’ in the definition of Intact Forest Landscape include fire suppression?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, FSC-DIR-40-005
PublishedWednesday, 09. July 2014

Answer

Regarding definition of Intact Forest Landscape, firefighting or prevention for the protection of public safety is not considered an economic activity. Fire control in the context of forest management activities is not considered to be an economic activity of minimal disturbance.

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Question

With regards to Category 3 (HCV), what is the minimal level of detail for describing the sourcing in the district of origin in the published company risk assessment? If the district of origin includes potentially controversial sources, when the company describes their sourcing in this area, must the description of their sourcing explicitly state that they are not sourcing from controversial FMUs in that district?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, FSC-DIR-40-005
PublishedWednesday, 09. July 2014

Answer

The minimum required information to be included in the publically available results of the risk assessment are provided in FSC-DIR-40-005-07, which applies to all CW categories. In case of potentially controversial activities in FMUs located in a low risk district (See FSC-DIR-40-005-02), a company should mention the existing FMUs with potential controversial activities in the publically available results of a risk assessment.

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Question

How should companies treat ecoregions that are not within the WWF Global 200 but are listed as ‘critical/endangered’ or ‘threatened’ by WWF? Should this information always be included in risk assessments, under 3.1?

Normative ReferenceFSC-STD-40-005 V2-1, FSC-DIR-40-005
Requirement(s)FSC-STD-40-005 V2-1, FSC-DIR-40-005
PublishedWednesday, 09. July 2014

Answer

The standard requires consideration of ‘ecoregionally significant HCVs’ and does not limit the recognition of ecoregions to Global 200 ecoregions. General references provided in the standard direct to WWF sources without limitation to Global 200 ecoregions (FSC-STD-40-005, Annex 1, definition of ecoregion). Therefore, information about threatened ecoregions other than the examples provided in FSC-STD-40-005 and FSC-DIR-40-005 should be taken into account. The company shall not ignore known and available sources of information in addition to the ones listed in normative documents.

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Question

If a company receives a complaint regarding their risk assessment and/or company verification program, does it matter if the complainant identifies the complaint as formal or informal as per the FSC Dispute Resolution Process?

Normative ReferenceFSC-STD-40-005 V2-1
Requirement(s)FSC-STD-40-005 V2-1, Section 14
PublishedWednesday, 09. July 2014

Answer

No, it does not matter. The company is required to deal with all complaints that are received according to the requirements of Section 14 of FSC-STD-40-005, irrespective of the complaint classification by a complainant. Controlled Wood requirements for the handling of complaints by Certificate Holders are not subject to the FSC Dispute Resolution Process and shall be evaluated by the Certificate Holder, according to their own mechanism.

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Question

How should a risk assessment be conducted following Clause 2.5 when ILO 169 is not ratified?

Normative ReferenceFSC-STD-40-005 V2-1
Requirement(s)FSC-STD-40-005 V2-1, Annex 2, part B, Section 2
PublishedWednesday, 09. July 2014

Answer

The standard does not refer to the ratification of ILO 169 and a risk assessment shall involve an assessment of evidence of violation of ILO requirements, irrespective of whether they have been ratified by the country in which the risk assessment is made.

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Question

Can material originating from artificially submerged forests be evaluated according to the standard FSC-STD-40-005?

Normative ReferenceFSC-STD-40-005 V 2-1
Requirement(s)FSC-STD-40-005 V 2-1
PublishedMonday, 19. May 2014

Answer

Materials harvested from standing “dead” forests that have been e.g. submerged to construct water reservoirs or damns are eligible for evaluation under the FSC Controlled Wood Standard FSC-STD-40-005 V2-1. In this case the district shall be set at the submerged area in question.
When evaluating conformance with the standard, special attention shall be given to the requirements of Controlled Wood Categories 2, 3 and 4, which, depending on circumstances, may be particularly challeng-ing to be met.
This interpretation supersedes any former interpretations relevant for this question.

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Question

Which process shall be implemented if a certified FMU is under suspension in a district that has been designated as low risk for all CW categories either by a National Risk Assessment or by a COC Certificate Holder in their FSC Controlled Wood verification pro-gram when the COC Certificate Holder wants to source from this FMU?

Normative ReferenceFSC-STD-40-005; FSC-DIR-40-005
Requirement(s)Clause 11.1 of FSC STD-40-005; ADVICE-40-005-07 of FSC-DIR-40-005
PublishedWednesday, 05. February 2014

Answer

At the moment of suspension the products sold by the certified FMU* are losing their FSC status. As the FMU is located in a designated low risk district for CW, the products may still be sourced as “controlled material” under the following conditions:

1. As some or all CW categories may be affected by activities that led to the suspension of the FMU, the COC Certificate Holder shall review and if necessary revise their risk assessment for the area of the suspended FMU.

2. The review/revision of the risk assessment shall be completed by the COC Certificate Holder within a period of two months from the date of suspension of the FMU certificate.

3. The COC Certificate Holder shall submit the reviewed/revised risk assessment to their CB for verification.

4. The reviewed/revised risk assessment shall be verified by the CB no later than one month after the COC Certificate Holder has submitted its reviewed/revised risk assessment, before it can be applied (see FSC-STD-40-005 V2-1 Clause 11.1).

5. As the whole district is considered low risk, the products sourced from the suspended FMU are considered controlled until the verification of the reviewed/revised risk assessment is completed by the relevant CB.

6. The outcome of the review/revision process including verification by the relevant CB will then determine the risk designation for the suspended FMU.

7. Material sourced from the area shall be classified as unspecified risk, if the timelines of review/revision and verification of the risk assessment (2, 4) is not met.

* according to the standard FSC-STD-01-001 or FSC-STD-30-010

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Question

In 2012 the Corruption Perception Index (CPI) changed from a scale of 0-10 to a scale of 0-100. Shall the new 0-100 CPI scale be implemented in FSC normative documents that currently still reference the previous 0-10 scale system?

Normative ReferenceFSC-STD-40-005, FSC-STD-20-011, FSC-DIR-40-005, FSC-STD-20-011
Requirement(s)Applies to all requirements where the CPI is mentioned
PublishedFriday, 06. September 2013

Answer

Yes, CPI references in FSC normative documents using the 0-10 scale system shall be converted to the new scale.

A reference to a CPI index threshold ʻ5ʼ based on the old scale system becomes a CPI index ʻ50ʼ applying the new scale.

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Question

Can wood from plantations converted to non-forest use be acceptable according to Category 4 of CW Standard FSC-STD-40-005?

Normative ReferenceFSC-STD-40-005
Requirement(s)Annex 2 and 3.
PublishedFriday, 04. May 2012

Answer

Yes, wood from plantations converted to non-forest use is acceptable according to Category 4 of FSC-STD-40-005.

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Question

Within a National Initiative “unspecified risk” category, is it possible for a company to classify a smaller district as “low risk”?

Normative ReferenceFSC-STD-40-005 V2-1; FSC-STD-30-010.
Requirement(s)Annex 3
PublishedTuesday, 31. January 2012

Answer

No, unless done at the FMU level through the process described in Annex 3 of FSC-STD-40-005. According to this standard, where national or regional interpretation or guidance relating to Annex 2 has been provided by an FSC accredited National Initiative, this interpretation shall prevail.

Other option would be that the Forest Manager got certified according to FSC-STD-30-010.

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Question

What is the definition of FMU in FSC terms and does this definition count for all references to FMU in FSC Standards, including Controlled Wood?

Normative ReferenceFSC-STD-40-005 V2-1
Requirement(s)Annex 2, A.3
PublishedThursday, 08. December 2011

Answer

Yes, the definition of FMU is the same for all references in FSC Standards, including Controlled Wood.

Forest Management Unit (FMU):
A clearly defined forest area with mapped boundaries, managed by a single managerial body to a set of explicit objectives which are expressed in a self-contained multi-year management plan.

The term ‘management plan’ is key and taken as equivalent to that which is described in FSC Principle 7.

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Question

In the previous FSC-ADV-40-016, section C.1 stated that risk assessments must be made available in one of FSC's official languages. However, ADVICE-40-005-07 in FSC-DIR-40-005 the requirement to use one of FSC's official languages is not included. Can you confirm that an official FSC language is not required anymore for risk assessment public summaries?

Normative ReferenceFSC-DIR-40-005
Requirement(s)ADVICE-40-005-07
PublishedFriday, 16. July 2010

Answer

Yes, based on the current directive, risk assessment public summaries do not need to be posted in the FSC database in an official FSC language (English or Spanish).

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