FSC has launched the second round of consultation for the revised Chain of Custody (CoC) Standard. Sensible changes, says NEPCon CoC expert Roman Polyachenko, who welcomes the new draft.
The second draft of the revised FSC CoC Standard (FSC-STD-40-004) is now available for public consultation.
“The key change in the new standard concerns the requirement to verify transactions. This is a new obligation, which represents a necessary tightening of the system against errors and fraud. FSC has provided flexibility for the industry with regard to how they meet this new obligation, and experience has so far shown that it is feasible to comply”, observes NEPCon Chain of Custody Programme Manager Roman Polyachenko.
“The draft also implies increased flexibility of the FSC Credit system, by allowing shared credit accounting in multiple-site certification," he says. "It should be noted that this is a point of contention amongst the FSC stakeholders, who are concerned about the credit system in general. The credit account system essentially disconnects the FSC product from the forest, and shared credit accounting across multiple sites accentuates the issue."
He highlights a key benefit of the revision: “The revised standard includes all the mandatory obligations and interpretations that have been scattered about in advice notes and other documents. Including all requirements in a single document makes it easier for users to maintain the overview. In addition, it includes a number of minor adjustments and clarifications that all make good sense and improve the standard overall.”
Key changes
The revised draft standard includes the following key amendments compared to the existing rules. Figures in brackets refer to sections/clauses of the draft standard.
Note: These changes are part of the draft standard. They are only out for consultation and thus not adopted yet.
-
Pre-consumer reclaimed paper counts as a claim-contributing input. Such material may thus be included in percentage or credit calculations. Note: The change concerns only paper, not wood. (Annex E)
-
Transaction verification: The draft standard includes a new requirement to introduce a system, which allows certificate holders to verify that the supplier’s sales claim registrations correspond with their own input claim registration. This requirement addresses the risk of errors or fraud where suppliers includes an FSC claim on their outgoing sales documents, but do not register this certified sale in their own records. One option for meeting this requirement is to use FSC’s Online Claims Platform, however certificate holders are free to choose other solutions. (1.7)
-
Shared Credit Accounting: The draft standard allows sharing credits between participating sites in multi-site certification. (9.2 and 9.3)
-
The labelling threshold for the FSC Recycled label is reduced from 85% to 70%. (10.1)
-
Credit system requirements: Key points include a) clarification of credit accounting for assembled products and b) extension of the period for credit expiration from 12 to 24 months. (Section 9)
-
Incorporation of advice notes and standard interpretations: All related advice notes and other mandatory interpretations are now conveniently built into the draft standard. (1.6, 2.4, 2.6, 6.3, 6.7, 6.8, 11.2, 11.11, 12.1)
Provide your input
You can submit your comments on the new draft standard until 31 October 2015. Find more information on FSC’s website.