The FSC Controlled Wood program was created for manufacturers and traders to avoid mixing timber and timber products from unacceptable sources with FSC certified materials. The Forest Stewardship Council® (FSC®) has published the new version of the Controlled Wood standard (FSC-STD-40-005 V3). The revision of the Controlled Wood standard is based on the June 2011 General Assembly, where a vote by the FSC membership passed Motion 51, Strengthening the Controlled Wood System. As a result of a continued wide discussion among stakeholders, the FSC Membership decided to revise and strengthen the Controlled Wood standard. The new Standard for Company Evaluation of Controlled Wood (FSC-40-005 V3) is one of the outcomes of FSC’s effort to follow up on this motion.
The “effective date” for this new standard version is 1 July 2016. The revised standard will require companies to implement a due diligence system to assess and mitigate risk within their supply chains. If you are an FSC chain of custody certified organization that mixes FSC certified materials with non-certified materials, this revision will have an impact on your certification systems.
As a major certifying body for the FSC, the Rainforest Alliance is ready to help guide companies through the transition process.
To help you navigate the various aspects of the upcoming transition, we have synthesized our guidance into 2 main sections.
- Transition Period
- Due Diligence System (DDS)
The Transition Period
- FSC defines a transition period as the period of time (usually 1 year) after the effective date in which the new version of an FSC normative document is phased-in and the old version is phased-out (where it exists). To allow for gradual introduction, both versions are valid for an overlapping period of time. Six (6) months after the end of the transition period, certificates issued against the old version are considered invalid.
- The Rainforest Alliance explains the process as follows: Certificate Holders (CHs) may make use of a transition period of 12 months from the effective date of the standard. This means that CHs can chose which version of the standard to be audited to after the effective date (1 July 2016). However, CHs must have an evaluation to the new version of the standard (FSC-STD-40-005 V3) by 30 June 2017.
- If companies choose to be audited to the old version (V2-1) during the transition period, they must be prepared to have an additional audit within this 12 months to transition to the new version (V3). This may be as simple as having your 2017 annual evaluation earlier in the year, or having two audits in calendar year 2017.
- There is a six month period after the transition period, ending 31 December 2017, where certificates issued to the old version (V2-1) of the standard can remain active. This six month window allows companies who have had an evaluation to the new version (V3) according to the transition rules to address any nonconformance reports (NCRs) raised during their evaluation. At the end of this six month time period certificates issued to FSC-STD-40-004 V2-1 are considered invalid.
Developing and Implementing a Due Diligence System (DDS)
Version 3 of the Controlled Wood standard contains new requirements for companies to establish and implement a Due Diligence System (DDS) that effectively allows companies to assess and mitigate risks within their supply chains. The DDS requirements differ from the previous requirements of a CW Verification program. Here are a few changes to consider:
- The DDS must include all suppliers and sub-suppliers of the material being assessed.
- The organization shall conduct internal audits of its DDS annually, including the implementation of timely corrective actions for any nonconformities found during the internal review.
- There are increased requirements for obtaining information on material.
- “Keep records of country and district of origin” is changed to “maintain evidence of the origin of material.”
- Companies must have access to information on its supply chains (including sub-suppliers) to a level that allows it to confirm and document risk related to mixing with non-eligible inputs.
- Companies are required to have a system to ensure suppliers notify it of any changes that may affect the risk designation or mitigation measure in place (e.g. change in species, origin or supply chain).
- New extended risk assessment for use by companies who are sourcing from countries that are not planned to have a risk assessment by 31 December 2017.
- Use of control measures designed to mitigate specified risks, rather than a mandatory sampling of Forest Management Units for field visits.
Companies can choose to develop their Due Diligence Systems or contract an outside party. The Rainforest Alliance cannot do such work for its own certificate holders.