Global P&C

FSC recently published a new draft of the P&C implying major changes, and now is the time to present your comments on the proposed new framework for FSC forest certification worldwide. Stakeholder feedback is invited until the 4th of September.

Same frame, new contents

The overall framework remains familiar: There are still 10 main principles, each supplemented by a number of criteria for forest management. As before, this is the framework for development of the national or regional FSC standards including indicators for each criterion.

It is in the actual wording of the principles and criteria that you find the proposed changes, some of which are quite significant.

New principle covers Management Activities

One of the key proposed changes is a new principle 10 for management activities, replacing the former Plantation Principle. The criteria under the principle are partly new and have partly been moved from other principles. 

Plantations are no longer covered by a special principle, following a recommendation from the plantation working group. This does not mean that plantations are now excluded from FSC certification. The difference is that plantations simply have to follow the same rules as other types of forest, and do not have to follow additional rules any more.

Climate change considered – but not enough

Principle 10 includes a new reference to the role of forests in climate change. Criterion 10.2 mentions adaptation to climate changes as a factor to be considered in species selection. Taking into account the drastic climate changes predicted within the next 50-100 years, we would have expected FSC to focus much more on ensuring that operations are taking actions to stabilise the forest in the face of climate change.  

The accompanying guidance notes repeatedly stress the role of fire prevention, which seems absolutely warranted. Fire prevention is often crucial for forestry to play a good role in climate change. At the same time, the new standard recognizes the positive role played by controlled use of fire in forest management.

Criterion 10.8 requires certified operations to take measures against the release of avoidable amounts of greenhouse gasses. This might have huge implications for forests and plantations established on drained peat land and other soil types with significant organic contents. Drainage of peat lands is known as an important factor in climate change. However, the current guidance to the criterion does not address this issue. Instead, it focuses mainly on the operation’s use of fossil fuel, logging techniques and fire protection.

Will FSC play a role in legality certification?

Principle 1 covers legality of forest operations, and includes 10 criteria bearing a strong resemblance to the Rainforest Alliance standard for Verification of Legal Compliance. The new principle 1 might be used as a stand-alone standard for verification of legal compliance, which could indicate that FSC is considering playing a role in the area of legal verification in the future. With the recent inclusion of forest products under the US Lacey Act and the EU plan for introducing a due diligence system, the focus on legality verification is growing rapidly these years.

New principle covers workers’ rights

Principle 2 focuses now on workers’ rights and conditions. Compared to the current standard there is an increased focus on ILO conventions, but in practice we don’t see major changes in the requirements. However, the proposed new standard asks certified organisations to promote gender equality, an issue that is not currently addressed. 

Will the reqirements for set-aside areas be softened?

A new principle 6 with the heading “Ecosystem Functions” includes new wording regarding set-aside areas (6.4).

The current standard requires that “representative samples of existing ecosystems ... shall be protected in their natural state”. Based on this criterion, about 1 million hectares of forest are today strictly protected by operations serviced by NEPCon alone.

The proposed new wording is softer, allowing the areas to be protected in both natural and semi-natural state. This may indicate that logging can continue to take place in the set-aside areas. Also, the new wording and related guidance seem to imply that some operations may be exempted from setting aside any areas. 

What about small-scale forests?

In recognition of the special challenges faced by small-scale private and community forests, taking steps to facilitate their certification is identified as one of FSC’s top priorities. This was confirmed at the FSC General Assembly held in November last year. 

The proposed new version of the P&C is not very helpful for small-scale operations. Although it does refer to the related motion passed by the General Assembly, only the very smallest operations (Small and Low Intensity Managed Forests, SLIMF) are addressed - and only with respect to one criterion in the whole standard (Criterion 2.3).

Nothing else in the draft version indicates that it will be easier for small operations to get certified. On the contrary, the standard introduces new requirements and is getting more complex. Overall, small-scale operations appear to have been inadequately addressed.

Missing issues

Some issues do not appear to have been addressed at all in the new standard:

• While other recent FSC standards have included requirements for quality management systems - such as procedures for ensuring compliance with the certification requirement, appointment of responsible staff, qualification requirements, and requirement for record keeping etc. - this is lacking in the proposed new version of the P&C.
• Another omission is the rules for sales of certified forest products (chain of custody). In fact, 99 pct of the certified operations expect to sell certified products. The FSC system today has no rules covering this, since the FSC chain of custody standard (FSC-STD-40-004) is not applicable for Forest Managers. At a minimum we would expect the new standard to include requirements for using correct claims on sales documents, such as certification code and the type of material (FSC Pure).
• Finally, the draft standard is missing references to trademark rules. While the current trademark rules for on product and promotional use are applicable for forest managers, the standard should include at least a reference to these requirements.

Need to improve structure and language

The first half of the standard has been more logically structured and more clearly worded compared to the current version. Unfortunately, this is not the case for the last part of the standard. For example, Principle 9 covers high conservation value forest as in the current standard, and the existing problem of overlaps with at least 4 other principles (4,6,7 and 8) remains.

It is clear that care has been taken to ensure correct and precise language. However, in some paragraphs the result is an academic and not very user-friendly language. The FSC Principles and Criteria should ideally use a straightforward language, so that most stakeholders immediately understand the meaning of the global rules.

Long process

The current version of the standard is out for public consultation until September 4th. The stakeholder input will be analysed and after that FSC expects to run a second public consultation before presenting a final draft for vote among the FSC members in late spring 2010. We can therefore expect several changes before we see the final new version of the FSC Global Principles & Criteria for Forest Management.

And even when the new version has been approved it might take years before the new requirements reach the forest manager. FSC National Initiatives need to update the indicators in the national adapted FSC standard and get them approved by FSC – a process that usually takes years. In the most optimistic case we may see the first operational standards based on the new requirements sometime late 2011.