Forest Stewardship Council FSC PROCEDURE. Minor Components Derogation Applications and Evaluations FSC-PRO (V2-2) EN CHAIN OF CUSTODY

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1 Forest Stewardship Council FSC PROCEDURE Minor Components Derogation Applications and Evaluations FSC-PRO (V2-2) EN CHAIN OF CUSTODY

2 Title: Document reference code: Scope: Approval: Contact: for comments: Minor Components Derogation Applications and Evaluations FSC-PRO (V2-2) EN International Version 2-2 approved by the Head of the FSC Policy and Standards Unit on 08 December 2010 FSC Policy and Standards Unit 2010 Forest Stewardship Council, A.C. All rights reserved. No part of this work covered by the publisher s copyright may be reproduced or copied in any form or by any means (graphic, electronic or mechanical, including photocopying, recording, recording taping, or information retrieval systems) without the written permission of the publisher. FSC-PRO (V2-2) EN FINAL VERSION The Forest Stewardship Council (FSC) is an independent, not for profit, non-government organisation based in Bonn, Germany. The mission of the Forest Stewardship Council is to support environmentally appropriate, socially beneficial, and economically viable management of the world's forests. FSC develops, supports and promotes international, national and regional standards in line with its mission; evaluates, accredits and monitors certification bodies which verify the use of FSC standards; provides training and information; and promotes the use of products that carry the FSC logo. 2 of 11

3 Foreword The FSC Board of Directors had agreed at their 46th meeting in November 2007 that the use of minor components between 1% and 5% of the volume or weight of the virgin and reclaimed materials in an FSC-certified assembled product shall follow clear procedures and mandated the FSC Policy and Standards Unit to develop and implement them. The objective of this procedure is to ensure that non-eligible input material is only included by this amount in minor components of FSC-certified products when there is a clearly demonstrated need and when there are provisions in place to phase out the use of such material and replace it by eligible input material accordingly. Note on use of this procedure This procedure shall be used in conjunction with FSC-STD : FSC Standard for Chain of Custody Certification. All aspects of this document are considered to be normative, including the scope, effective date, references, terms and definitions, tables and annexes, unless otherwise stated. Please send any comments or suggestions regarding this document to: FSC International Center Policy and Standards Unit Charles-de-Gaulle Str Bonn, Germany Phone: / Fax: / policy.standards@fsc.org 3 of 11

4 CONTENTS A B C D Scope Effective date References Terms and definitions PART I: APPLICANT RESPONSIBILITIES 1 Submission 2 Technical specifications 3 Material demand and current supply 4 Market supply analysis PART II: CERTIFICATION BODIES RESPONSIBILITIES 5 Evaluation and decision making 6 Information 7 Extension of a minor component derogation ANNEX 1: Application and Evaluation Form for Minor Components Derogation 4 of 11

5 A Scope Part I of this procedure applies to Chain of Custody organizations when applying for the use of non-eligible input material in minor components constituting between 1% and 5% of the volume or weight of the virgin and reclaimed materials in an FSC Pure or FSC Mixed assembled product (to be) certified according to FSC-STD : FSC Standard for Chain of Custody Certification. Part II applies to the certification body for the purpose of evaluating and deciding on the applications. B Effective Date Effective upon approval. C References The following referenced documents are indispensable for the application of this document. For undated references, the latest edition of the referenced document (including any amendments) applies. FSC-STD FSC Standard for Chain of Custody Certification FSC-STD a FSC Product Classification FSC-PRO a List of approved generic minor components derogations D Terms and definitions The definitions for key terms provided in FSC-STD : FSC Standard for Chain of Custody Certification and FSC-STD : FSC Glossary of Terms apply. In addition, the following terms are used in this document: Applicant: Organization that wants to use non-eligible input material for specified minor components in products as part of FSC product groups. Derogation: Temporary authorization to use non-eligible input material in minor components. 5 of 11

6 Without a valid derogation, use of non-eligible input material by an organization in minor components which constitute more than 1% of the volume or weight of the virgin and reclaimed materials in an assembled product shall prevent the issue of an FSC Chain of Custody certificate or, if the organization is an FSC Chain of Custody certificate holder, shall lead to the immediate suspension of the certificate. PART I: APPLICANT RESPONSIBILITIES 1 Submission 1.1 The applicant shall submit the derogation application for the use of minor components that constitutes between 1% and 5% of the volume or weight of FSC Pure or FSC Mixed products to its certification body for approval. 1.2 The application shall be submitted in writing using the form included in Annex 1. NOTE: A separate application shall be submitted for each minor component for which derogation is being sought. In total, minor components shall not exceed 5% of the volume or weight of an FSC Pure or FSC Mixed product. 2 Technical specifications 2.1 The applicant shall provide a description of the product(s) that the minor component will be used for, including: a) An overall description of the product(s); b) The product type(s) according to the FSC product classification (see FSC- STD a); c) The FSC product group claim (i.e. FSC Pure and/or FSC Mixed ); NOTE: Non-eligible input material may only be used in minor components as part of FSC Pure or FSC Mixed products. d) Intended use of an on-product FSC label (yes/ no). 2.2 The applicant shall detail technical and functional specifications of the minor component in terms of the following aspects: a) General description of the minor component; b) Common trade name, if applicable; c) Function of the minor component within the product; d) Volume/ weight of the minor component in total and in relation to the overall volume or weight of the virgin and reclaimed materials in the product; e) Species used for/in the minor component, if information on species composition is commonly used to designate the component s characteristics; f) Quality of input materials (e.g. grade, sort); g) Dimensions of the minor component. 2.3 The applicant shall provide a photograph or a technical drawing of the minor component. 6 of 11

7 3 Material demand and current supply 3.1 The applicant shall indicate its annual material demand for the minor component and specify its current supplier range and locations. 4 Market supply analysis 4.1 The applicant shall describe its undertaken activities to source materials for the specified minor component as eligible input. These activities shall include an analysis of the relevant market supply of virgin and/ or reclaimed materials suitable for use in the specified minor component, covering at least the following aspects: a) Available supply in terms of purchasable quantities; b) Current and potential supplier range and locations; c) Material category (FSC-certified, controlled and/ or reclaimed material). NOTE: Activities and market supply analysis are expected to be carried out according to the scale of the applicant s business activities and should include activities targeted at the applicant s supplier base, market researches through the FSC database of FSCcertified suppliers ( consultation of the nearest FSC National Initiative, and consultation of trade and industry associations. Activities may further include use of consultants or organizations operating as market experts. 4.2 The applicant shall demonstrate through the supply analysis that its annual material demand cannot be met by quantities of FSC-certified, controlled and/or reclaimed materials available on the relevant markets. In particular, the applicant shall explain the reasons why material used for the minor component cannot be sourced or assessed as controlled or reclaimed material. PART II: CERTIFICATION BODIES RESPONSIBILITIES 5 Evaluation and decision making 5.1 The appropriateness of the derogation application shall be evaluated by the responsible certification body resulting in one of the following decisions: a) Approval of the application (with or without conditions); b) Request for further information from the applicant; or c) Rejection of the application. NOTE: If the application is rejected, the applicant may modify the original derogation application or provide additional supporting documentation to respond to any issues identified by the evaluation, and then resubmit the derogation application. In this case, the steps established in Part II of this procedure shall be repeated. 5.2 Approval shall be granted for a maximum period of three (3) years. 5.3 The evaluation shall be carried out by use of the form provided in Annex 1 and any results and comments relevant for the overall decision shall be included. 5.4 The certification body shall accept appeals against the application decision by the applicant or complaints by any third party, and assess the provided evidence for its relevance to the decision accordingly. 7 of 11

8 6 Information 6.1 The certification body shall analyze the documents received from the applicant and provide a decision about the derogation request within one (1) month from the date of receipt. 6.2 For approved applications, the certification body shall send a PDF version of the completed application together with the decision to the applicant and upload the document in the FSC database ( as a non-public document. 7 Extension of minor component derogations 7.1 Applications for an extension shall be submitted to the certification body not later than three (3) months before the expiration of the approved derogation. The applicant may continue to use the minor component while the request for an extension of the derogation is being processed and a decision has been taken. 7.2 The certification body shall only grant an extension of derogation if: a) It can be clearly demonstrated that the relevant market supply of FSCcertified, controlled and/or reclaimed materials has not increased since the previous approval date; b) The applicant explored options to substitute non-eligible input materials, but without success. 8 of 11

9 ANNEX 1: Application and evaluation form for minor component derogations NOTE: Sections A to C of the form shall be completed by the applicant. The certification body will check the completeness and appropriateness of the information provided and shall complete Section D. A. General information Applicant: Organisation [legal name]: Certificate code [if applicable]: Country: Address: Contact person: Position: Application date: Component / product: Minor component [name/technical term]: Used in product(s): B. References to supplementary documentation NOTE: Please list all supplementary documentation that has been submitted for consideration with this derogation application. Document title 9 of 11

10 C. Specific / technical requirements NOTE: Please provide references to any documentation which has been attached to the application. 2 Technical specifications 2.1 Product description Comments a) General description [General description of the product(s) that the minor component is used in. If more than one minor component shall be used in the product, provide the relevant information] b) Product type(s) [According to the FSC product classification in FSC-STD a] c) FSC product group claim ( ) FSC Pure ( ) FSC Mixed d) Intended use of on-product FSC label ( ) yes ( ) no 2.2 Minor component Comments a) General description b) Common trade name c) Function within the product d) Volume/weight In total: As percentage of the overall volume or weight of the product: e) Timber species used f) Quality of input materials [e.g. grade/ sort] g) Dimensions 2.3 Photography / technical drawing Comments A photography or technical drawing of the product showing the minor components was submitted to Certification Body s analysis: [Please reference and attach] 3 Material demand and current supply ( ) yes ( ) no 3.1 Annual material demand Comments Specify the annual material demand: Current supplier range and locations: [list main suppliers and geographic location if international, country level is sufficient] 10 of 11

11 4 Market supply analysis [Please make sure that you provide / attach detailed information of the undertaken activities such as e.g. a list of the contacted suppliers, examples of order requests and the corresponding responses, details of consultations carried out with market experts, FSC National Initiatives or WWF buyers groups, and correspondence / interaction with the relevant industry associations, to name the most important.] 4.1 Undertaken activities to source materials for the specified minor component as eligible input Market supply analysis of virgin and/or reclaimed materials suitable for use in the production of the specified minor component: a) Available supply in terms of purchasable quantities b) Current and potential supplier range and locations c) Material category (FSC-certified, controlled and/or reclaimed material) 4.2 Demonstration that annual material demand cannot be met by quantities of FSC-certified, controlled and/or reclaimed materials available on the relevant markets Explanation of reasons why material used for the minor component cannot be sourced or assessed as controlled material (according to FSC-STD ) or reclaimed (according to FSC-STD ): Overall results: Comments Comments D. Derogation Decision This section shall be completed by the Certification Body. Certification Body Information: Certification Body: Evaluation carried out by: Position: Decision: Evaluation date: Result 1 : Expiry date: Conditions (as applicable): 1 See Clause of 11