What you need to know about the new FSC Controlled Wood standard V3-1

The Controlled Wood standard applies to all organisations that source material from non-certified forest areas and wish to make Controlled Wood or FSC Mix claims.

Note that this article provides an overview of the main changes in the standard. For a full overview of the requirements, you will need to consult the standard itself.

Summary

• You now have until 31 December 2017 to get audited against the new Controlled Wood standard – an extension of six months. If you’ve been audited against the CW standard version 3-0 by 30 June 2017 then you don’t need to have a second audit in 2017.
• If you want to demonstrate your compliance with the EU Timber Regulation, then you must use the new version of the FSC risk assessment[1] for category 1 instead of the old national risk assessment. The implication of this is that FSC acknowledges that if you are currently using a previous version of the Controlled Wood standard, you cannot assume that this wood was legally harvested, transported and traded. 
• You are allowed to continue using the old national risk assessments until 31 December 2018.
• You are now allowed to use individually approved[2] categories of either centralised national risk assessments or national risk assessments instead of waiting for the full risk assessments to be approved and finalised.
• You are now allowed to continue to use a simplified risk assessment (now known as a company risk assessment) if there is no centralised national risk assessment or a national risk assessment available for the country.

Transition period extended

You will probably be pleased to read that you have a bit longer to get ready for your audit against the new Controlled Wood standards than before.

The new deadline is 31 December 2017. This is the date by which you have to have been audited against standard 3-1. It’s an extension of 6 months over the previous deadline.

Note though that if you get audited against version 3-0 before 30 June 2017, then you do not have to get re-audited against standard 3-1 before the end of December 2017.

EUTR compliance

FSC has introduced a new requirement to better align the Controlled Wood standard with the EU Timber Regulation. Indeed, FSC states that one of this was one of the main reasons they introduced the new version. The implication of this is that if you are currently using a previous version of the Controlled Wood standard, you cannot assume that your wood has been legally harvested, transported and traded, and will therefore need to carry out due diligence to assure yourself of this. 

It has been concluded that ‘old’ national risk assessments[3] do not include a legality definition (CW category 1) that meets the EUTR. Therefore, it cannot be assumed that material sourced against these risk assessments can be assigned a low risk of breaching all applicable harvesting, transport and trading laws in its country of harvest – as per the EUTR definition.

Version 3-1 of the standard requires that if you want to use Controlled Wood certification as part of your due diligence system, then you must use a draft FSC risk assessment[4] for category 1 instead of the old national risk assessment.

NEPCon welcomes these changes. We previously highlighted how, without these changes, Controlled Wood would have reduced value as a risk mitigation measure under the EUTR.

National risk assessments

There are two changes relating to national risk assessments in the new version of the Controlled Wood standard.

First, the deadline for using the old national risk assessments has been extended by a year. If you are using an old national risk assessment you will now be able to continue to do so until 31 December 2018. If there’s a new national risk assessment completed before this date, then you must move over to using the new one.

If FSC has not published a new national risk assessment by 31 December 2018, then you must stop using this assessment and should assume that the area is unassessed.

Secondly, you are now allowed to use certain parts of a draft national risk assessment - the categories that are agreed upon by national consensus – before the whole assessment has been finalised.

If you need to find out the status of the risk assessments that are relevant for you then go to the FSC website and then click on the right to ‘view the current timetable for CNRA and NRA development.’

Company risk assessments or simplified risk assessments

FSC has changed the name of these assessments from ‘simplified risk assessments’ to ‘company risk assessments’.

There used to be a deadline of 31 December 2017 by which you had to stop using a risk assessment developed by your company. The new version of the standard removes this deadline. In other words, you are now allowed to use a company risk assessment as long as there is not a centralised national risk assessment or a national risk assessment available for the country.

Document centre

FSC has created a new document centre where you can find all FSC policies, standards, directives, advice and interpretations, as well as all of the risk assessments. It’s available at https://ic.fsc.org/en/document-center

This changes means that you are no longer required to use the Global Forest Registry to get the risk assessments– you can now find them on FSC’s own website.

[1] Developed according to FSC-PRO-60-002 V3-0

[2] For CNRA’s approved categories can be used, and for NRA’s the categories agreed by national consensus. Information about which categories are approved or agreed upon can be found on the FSC website https://ic.fsc.org/en/what-is-fsc-certification/controlled-wood/risk-assessments

[3] An ‘old’ National Risk Assessment is one developed according to FSC-PRO-60-002 V2-0

[4] A ‘new’ National Risk Assessment is one developed according to FSC-PRO-60-002 V3-0