Controlled Wood - new advice

The guidance, which is mandatory and effective immediately, covers several issues that were highlighted during the FSC General Assembly about six months ago.

FSC LISTENED TO ITS STAKEHOLDERS

The process of developing the advice note initially involved several turnaround interpretations, which were not in line with the messages expressed by the FSC General Assembly in November 2008.

Among these was a proposal to accept supplier declarations on the origin of the wood in place of solid documentation - while the membership had asked for stricter implementation of the existing requirement for such documentation. 

Following consultations, such inconsistencies have been removed from the final advice, and the guidance now in place is in accordance with the motions passed by the FSC membership. The process shows that controlled wood remains one of the most debated and controversial topics in the FSC system.

WILL THE GUIDANCE IMPROVE PERFORMANCE?

The updated advice note does not imply major changes compared to previous guidance, but stresses and elaborates on certain points. 

Although the adjustments are certainly helpful, proper surveillance of the certification bodies’ performance clearly remains key to realise the central point of the FSC General Assembly motions: Stricter implementation of the already existing requirements.

Weak performance by companies as well as certification bodies in implementing the Controlled Wood rules is well known to be the key problem, and the guidance does not by itself change that situation.

KEY POINTS OF THE NEW GUIDANCE

Below, some key points from the new Advice Note are highlighted. For companies that need to comply with these rules, we do recommend to read the entire guidance carefully (see link below). 

Need to document origins 
As mentioned above, the requirement for documentation demonstrating the district of origin remains in place, and the new guidance even underlines that supplier declarations do not qualify as sufficient documentation to demonstrate the material's origin. The guidance also mentions supply chain audits as a possible instrument to verify origins when documentation is not possible or when there is a risk that the available documentation is inaccurate. 

New guidance on High Conservation Value Forest 
In relation to risk assessments, the advice note specifies a new source of information as possible evidence for protection system in relation to HCVF forest areas: World Bank “rule of law” index, which needs to be above 75% for positive conclusion (www.govindicators.org). It also includes more specific information in relation to considering High Conservation Value Forests within the risk assessment preparation process. 

National Initiatives' guidance now mandatory 
The advice note further specifies that any formal guidance provided by National Initiatives (even if it does not constitute a full risk evaluation approved by FSC International), shall be taken into consideration by companies in relation to the risk assessment. 

Annual reviews of risk assessments 
Companies are required to review their risk assessment at minimum once per year, and update it in case there are any changes in the risk profile. For example, the situation in the district of origin may have changed, FSC National Initiative may have published specific guidance, etc. 

Consultations required in case of complaints 
In cases when a formal complaint is submitted to the certified company regarding controversial activities in a forest from where material is being sourced, FSC now requires the company to conduct stakeholder consultations to follow up on the complaint. 

Some non-conformances still to be classified as major 
Although this aspect has not changed compared to the previous FSC advice, it should be noted that several non-conformances are listed which shall be immediately classified as Major by certification bodies. Among others, this includes the absence of eligible documentation to demonstrate the district of origin for each supply; failure to submit a new risk assessment for review and approval to the certifier prior to using inputs from the new district; incomplete or lacking risk assessment; and absence of a complaints mechanism.