Controlled wood - motions

It was probably also the most frequently discussed topic at the event. 

Problems of enforcement

Four years have passed since FSC introduced the Controlled Wood requirements together with the credit system and changes in the Chain of Custody standard. You might have expected that the system would be well implemented by now. Unfortunately, this is not the case, which has caused major concerns among members and other stakeholders of FSC.

The key motions related to the Controlled Wood on the General Assembly focus more on implementation of the existing rules than on changing the rules. There seems to be a clear understanding that the current rules in general are sufficient to avoid wood from unacceptable sources entering FSC products, but only if implemented as intended.

Controlled wood - a difficult baby

How did the controlled wood scheme come out of control? It seems that all parties - including FSC, Accreditation Service International, the certification bodies and the certified companies - have somehow all played their part. 

The controlled wood system has been a difficult baby for FSC from the beginning. When the standard was introduced in 2004, it was not properly worded and tested. The second version improved the situation – but still left some room for 'creative interpretation'. Most of these were finally closed by an advice note issued by FSC this spring.

Adding to the lack of clarity, there hasn't been sufficient focus on enforcement of the rules. Although ASI finally announced strict enforcement of the requirements this spring, much work still remains to be done before they are properly enforced. E.g. a short search on the FSC certificate database www.fsc-info.org shows that summaries of risk assessments are still not published for most of the companies certified according to the controlled wood standard. 

It is problematic if certification bodies are allowed to use a weak interpretation of the controlled wood standard. The requirements can be both complicated and expensive to implement as intended, so naturally certified companies will choose the cheapest and easiest option accepted by their certifiers. 

Motions to put controlled wood back on track

The main focus of the motions is therefore to ensure that the controlled wood requirements are enforced by all parties and that more guidance is prepared.

Motion 23 requires that “an immediate monitoring, evaluation, and reporting system is put in place to review the implementation of the currently valid Controlled Wood  system”, and motion 24 says: “FSC will ensure transparency in the process of risk assessments and their public availability, whilst maintaining supply chain confidentiality”.

Both requirements are already in place and should be verified as a part of the accreditation system – but  stricter enforcement is obviously needed. Similarly, motion 24 repeats that CBs shall follow the existing requirements related to proof of origin: “FSC will ensure that existing requirements for proof of origin are properly implemented by Certification Bodies”.

Motion 24 also includes a couple of new requirements. In case of multiple complaints about a Forest Management Unit (FMU), the entire FMU shall be evaluated directly by a certification body based on the FSC-STD-30-010, which is the controlled wood standard for forest enterprises. The requirements for field verification in case of “unspecified risk” for high conservation value forest will also be strengthened.

Furthermore, motion 24 asks FSC to develop additional guidance including guidance to FSC National Initiatives on conducting risk assessment and guidance on stakeholder consultation and interpretation of the High Conservation Value Forest concept within the standard. The Global Risk Assessment shall also be further developed.

Motion 23 requires a general evaluation of the controlled wood concept within the next 3 years including exploration of the options to eliminate the controlled wood system, develop it further, and develop alternatives for ensuring a stronger uptake of the FSC certified wood.

What are the implications for certified companies?

For most certified operations already having an approved and summary of uploaded risk assessment on www.fsc-info.org and which are able to trace the wood back to its origin, the motions will have no implications. Also, companies sourcing controlled wood from already certified companies can rest assured. The motions are only aimed at companies sourcing form uncertified sources and implementing their own verification program.

For companies without an approved and published summary of risk assessment, and for companies implementing their own verification program without proper documentation for tracing the wood back to the forest of origin, the motions might have significant implications. Such operations should contact their certification bodies for further guidance.

The benefits of controlled wood

Considering all the challenges with implementing the Controlled Wood requirements, it may be justified to ask if it has been worth all the trouble.

NEPCon firmly believes so; with proper enforcement and additional guidance, the standard can still be an efficient tool to avoid wood from unacceptable sources entering into products carrying the FSC label.

Without the controlled wood standard and the related chain of custody credit system, FSC would not have solved the bottleneck problem among primary manufactures such as larger pulp mills and sawmills. A large part of recent years' exceptional growth in certified products on the market has been based on the use of these systems.