Transitory FSC requirements: register for extended deadline
Companies operating under the FSC transitory requirements for FSC labeling of chip/fiber products or using uncontrolled co-product inputs in their FSC products, should be aware of the nearing expiry of the transitory exceptions.
Obtain extended deadline by registering
Chipboard and fiberboard producers, sawmills, and other companies making use of these exceptions need to adapt to stricter requirements by 1 April 2011.
Uncontrolled co-product inputs - such as chip residues from sawmills – may no longer be used in FSC certified products; and the labeling threshold for FSC Mixed chip and fiber products increases from 50% to at least 70% FSC-certified and/or post-consumer reclaimed input material.
However, to allow companies to ease into these stricter requirements, FSC has published a new directive (FSC-DIR-40-004) introducing an option to register the relevant product groups in order to extend the deadlines for expiry of these previously approved product groups. The low labeling threshold for chip and fiber products can be extended for more than four years, while the option to include uncontrolled co-products in FSC-certified products can be extended for a maximum of 20 months.
Only product groups that are currently being produced under the transitory requirements can be registered.
Extension periods granted
Registered product groups for the uncontrolled co-product input exception must conform to the normal FSC Controlled Wood requirements (specified in the documents FSC-STD-40-005 and FSC-DIR-40-005) as of 1 January 2013. All non-registered product groups shall be in conformance with the normal Controlled Wood requirements as of 1 April 2011.
Registered product groups under the 50% chip/fiber labeling threshold must conform to a labeling threshold of 70% as of 1 January 2016. For all non-registered product groups, the 70% labeling threshold applies as of 1 April 2011.
Who needs to register?
Companies directly applying the transitory requirements in their production need to register the concerned product groups. Certificate holders operating a transfer system do not need to register their product groups in the following cases:
1. The material was received with an FSC on-product label. Please note that it is necessary to keep evidence that the received product was labeled by the supplier (e.g. in form of a product or package sample); or
2. If the material they receive has already been registered by a previous company, and this can be verified during audits. FSC provides the option for the supplier to include a 'registered' claim on their invoices and transport documents ("FSC X % registered"); the registered product status needs to be verified at the FSC database and the invoices and transport documents can be used as evidence that the received products were already registered by the supplier.
How to register
To request authorization, FSC-certified clients of the Rainforest Alliance and NEPCon need to submit the following documentation during March 2011. The exact deadline for submission and further information will be sent directly to our affected clients:
1. A list of FSC Mixed product groups with products labeled on the basis of a 50% threshold and/or products that contain uncontrolled co-products, using the product registration template as provided by your Rainforest Alliance/NEPCon contact;
2. Copies of sales invoices for the corresponding registered products as evidence that they have been commercially produced before the registration deadline.
This article was amended on the 19 February 2011 based on revisions to the directive done and communicated by FSC on 14 February 2011.
