Increased flexibility for using reclaimed materials in FSC products

“I expect the new standard to be welcomed by enterprises using reclaimed materials in their FSC products”, says Tammy Coe, Chain of Custody specialist at the Rainforest Alliance. “Many certificate holders will find increased flexibility in how they organise the supplier auditing programs. In some cases, the new standard enables the companies to replace supplier audits with material inspection and classification upon receipt, thus reducing the level of effort needed to maintain certification”. 

Key changes

The most important changes in the revised standard are:

• New Terms and Definitions, including 'Official Reclaimed Paper Classification and Assortment System' and 'Point of Reclamation'.
• Supplier validation requirements are outlined (section 2), including a clause (2.1.a) requiring certificate holders to keep a record of specific details related to their reclaimed material suppliers.
• Certificate holders are required to define a "contingency plan" when received material does not conform to standard requirements (clause 2.1b).
• Requirements for documenting such follow-up actions are defined (3.4).
• The new concept of material inspection and classification upon receipt is introduced, and the standard provides examples of "objective evidence" to be retained for each supply if an organization elects to use this method in lieu of a supplier audit program (section 3).
• Specific guidance is given for supplies that include a mixture of pre- and post-consumer inputs (3.5).
• The standad describes the supplier audit program, which is now only required for supplies that do not qualify for inspection/classification upon receipt (section 4). The evidence that shall be evaluated/documented in the supplier audit program is specified (4.4 and 4.5).
• Supplier audit requirements have been expanded to include details on supply chain auditing for cases where the supplier selected in the sampling sells reclaimed materials that were previously collected, classified and traded by other companies. The new version requires audits of the supply chain up to the point where the classification as pre-consumer and/or post consumer can be demonstrated through objective evidence (4.3). It should be noted that version 1 of the standard only required audits to the direct supplier, so in some cases this change may increase the number of supplier audits for a certificate holder sourcing materials that cannot be classified upon receipt using objective evidence.

There are no significant changes to the definition of pre- and post-consumer materials (Annex I and II).

Deadline for implementation

While the new version is required for all new certificates issued on or after 01 June 2011, all existing certificate holders shall be in conformance with this standard by 01 April 2012. FSC audits carried out after this date will be done according to this standard. 

However, due to the fact that the new standard offers more flexibility, companies using reclaimed materials may choose to switch earlier. Certificate holders that wish to implement Version 2, prior to their next annual audit may revise their systems and collect examples of objective evidence used to classify materials, if applicable. Revised documented procedures and examples of objective evidence shall be submitted to NEPCon/RA for desk approval; and conformance will be checked on-site at the next audit.