Forest Stewardship Council
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1 FSC Chain of Custody Standard Revision Webinars Questions & Answers Last update: 20 January 2015 COMPLAINTS SECTION 1. When does an inquiry or question rise to the level of a complaint? A complaint is an expression of dissatisfaction by a person or organization in relation to the company s conformity with the COC standard. An inquiry or question about any aspects of company s certification is not in principle a complaint, but it might turn into a complaint if not properly addressed by the company in the first instance (when the inquiry or question is first received by the company). 2. Is a clarification of a product claim considered a complaint? No. See answer above. 3. Can we not just incorporate the complaint in our normal process? Yes. If the organization already has a system in place for receiving and processing complaints (e.g. as required by other certification systems), the same procedures might be used and/or adapted to demonstrate conformity to FSC s requirements. 4. Why not have follow-up requirement become "a timely manner" instead of a fixed timeline. It is very hard to incorporate this into already in process ISO procedures when the timelines for varying standards differ. Timely manner is a very subjective term and difficult to be evaluated by the certification bodies. Following the feedback of stakeholders, FSC is now trying to avoid the use of subjective terms in the standards that might lead to different interpretations or uncertainties regarding the actions required to demonstrate conformity with a normative requirement : e) and the note are not consistent e) requires notification to clients after closure. note requires notification before closure Thanks for the feedback. Indeed, the last sentence of the note refers to e). We will review the clause to ensure that any possible inconsistencies are eliminated. 6. Can you give an example of a complaint? Complaints may refer for example to incorrect product labelling, discrepancies between product labels and FSC claims on invoices, when the product delivered does not meet 1 of 8 FSC International Center GmbH Charles-de-Gaulle-Straße Bonn Germany T +49 (0) F +49 (0) fsc@fsc.org FSC F Geschäftsführer Director: Dr. Hans-Joachim Droste Handelsregister Commercial register: Bonn HRB12589
2 the purchase specifications in terms of FSC certification (for example, the buyer ordered an FSC certified product and received FSC controlled wood). Complaints related to the quality of services or products are not covered by Clause PRE-CONSUMER RECLAIMED PAPER 1. I believe there was no official output of the results of the discussion paper. The process seems not transparent. Some stakeholders are really against the idea but their opinions seemed just ignored. FSC conducted a public consultation on the FSC Discussion Paper (FSC-DIS ) from October 2013 to January A follow-up report from FSC containing a synopsis of the stakeholder comments received during the consultation was published on May 8, This report is available for download at the following webpage dedicated to the study and discussion paper: Motion 38 Chamber balanced study on pre-consumer reclaimed paper and fiber. 2. This is great news! "will NOW be considered a claim-contributing input". As of now? This change will not officially occur until the revised standard has been approved and Certificate Holders have transitioned over to the new standard. The target effective date is currently January 1, Sorry for the confusion, we will correct that statement in future presentations. 3. Why is pre-consumer reclaimed wood not being considered? Motion 38 specifically asked FSC to evaluate the risks and benefits of valuing preconsumer reclaimed paper fiber materials as FSC certified content. Therefore the study did not include a review or evaluation of pre-consumer reclaimed wood. 4. If the proposal to give pre-consumer paper the same status as post-consumer, will be changed to reflect this change? No, the FSC Standard for Sourcing reclaimed material (FSC-STD ) does not address how Certificate Holders value pre-consumer reclaimed wood in their control systems. This is only addressed in the Chain of Custody Standard, and therefore there is no need to revise FSC-STD ASSEMBLED WOOD PRODUCTS AND VISIBLE WOOD COMPONENTS 1. Does this mean only when a product gives its name? Meaning that if a company chose to call a product by a generic name would be okay? As in, maple plywood would be okay if it was called hardwood plywood? 2 of 8
3 Yes, that is correct. Conformance with would only be required if the product contains a visible wood component whose species characterizes and gives its name to the product. 2. If a wood door is invoiced as a particleboard core door with Cherry veneer, would the Cherry veneer be required to be FSC Certified? Yes, the cherry would have to be certified as its species characterizes and gives its name to the product. 3. Credit system; assembled products: Must all parts be FSC certified or can a part be FSC Controlled Wood? Clause only applies where a product contains a visible wood component whose species characterizes and gives its name to the product. For further clarification on how the credit system can be applied by manufacturers of assembled wood products, please reference the section 9.3: Establishment of credit accounts. 4. If the veneer is certified and not the core, could this still be labeled as FSC? More information is needed to answer this question as this depends on the control system the Certificate Holder uses and whether the core is FSC Controlled Wood. If the core is FSC Controlled Wood then it is possible under specific predetermined control measures (e.g. if the FSC labelling requirements specified in Part III of the standard are met). 5. So if the species is mentioned it must be FSC-certified, but if you remove the species from the product name, does this mean that the product does not need to be certified? Seems misleading. Yes, this is correct, conformance with would only be required if the product contains a visible wood component whose species characterizes and gives its name to the product. This proposed requirement is intended to address a perceived misleading practice mentioned in Motion 43, where for example, the visible oak-veneer of an FSCcertified oak-kitchen is not certified, but controlled wood, and the remaining and nonvisible components (mainly chip or particle board) are FSC-Mix. As described in the motion, consumers would expect that the oak-veneer of this product to FSC-certified. 6. Plywood manufacturers often use FSC controlled wood as a face veneer and then indicate that the finished product is FSC Mix XX%. It sounds like this would no longer be allowed. Correct? 3 of 8
4 This would be correct only if the plywood contains a visible wood component whose species characterizes and gives its name to the product. TRANSACTION VERIFICATION 1. I believe it will be very difficult to match suppliers' internal records. This would appear to be very difficult. The Online Claims Platform has been designed to provide CH s with what they need to meet this criterion. However, other methods can also be used if a CH wishes. This can be manual verification or other automated systems that the organizations may already use. 2. Standard refers to "output claims" - what are output claims? Output claims are the FSC certificate holder s FSC sales. 3. Will OCP registration be required during 2015? No, FSC certificate holders will need to be in compliance with all elements of the CoC revised standard including the transaction verification criterion when the standard is approved. FSC certificate holders can register & use the Live OCP during the first quarter of 2015, and can test the OCP today. Click the Register & Try button to test the OCP today! 4. Isn't this already covered by the material sourcing requirements in the standard? Transaction verification verifies that the supplier s internal records include all of their FSC sales. Material sourcing requirements has to do with a Certificate Holder s purchases and sales, and does not cross reference their supplier s internal records. Go here for more information. 5. Question on OCP and inputs. Currently many companies purchase FSC certified raw materials but don't make use of those inputs in an FSC certified finished product (such as when a printer buys FSC paper but doesn t print an FSC certified printed piece or when a distributor buys FSC materials but sells them as non FSC). In these situations, the company is now required to record these inputs? FSC Certificate Holders are still only required to record the FSC certified inputs that they use (or may use) as FSC certified. Certificate Holders do not need to claim material they purchased that is FSC certified which they do not use/label/sell as FSC certified. 6. How do Groups fit into the recording of inputs? Is it now going to be the responsibility of Groups to provide this information for all Group members? Currently volume summaries 4 of 8
5 are only collected by the CB for the Group members being actually audited by the CB not for the Group as a whole. Individual sites/group members of multiple-site certificates will continue to be required to record their FSC inputs/outputs by specific site/group member and not the entire certificate. 7. What manual system are you suggesting for cross referencing of documentation verification? Manual systems include where a Certificate Holder chooses to send their suppliers Certification Body a list of their respective FSC certified purchases from that individual supplier, along with sending a list of their FSC certified sales to their respective customers Certification Body for review. 8. Please can you promote transaction verification webinars on the FSC website - currently no reference that I can see. The webinars can be found on the OCP Informational webpage, about half way down the Resources Page. 9. All of the standards have alternative options posed that include the CB auditing these options. Can you go over what FSC US is doing in terms of working with CBs to go over what a transaction verification means to the auditing body? FSC US is engaged with the OCP team regarding the development of criteria in the FSC accreditation standard (20-011) and will ensure that CBs are engaged in this process. Please join the OCP webinars for more information. If you have specific questions or feedback, please contact the OCP team. CROSS-SITE CREDIT SYSTEM 1. Am I correct that the proposal requires a site to contribute 10% of the FSC certified material used at that site, rather than the previous requirement that 10% of the site's total inputs must be certified? Correct, multi-site certificate holders who wish to maintain shared credit accounts must ensure that each site participating in a shared credit account shall contribute at least 10% of the input credits used by its own site in a twelve (12) month period. However, there is no previous requirement as this is a new requirement introduced to the Chain of Custody Standard. 2. Would you please provide more clarification on the use of the word 'ecoregion' in 9.1.3? 5 of 8
6 A reference will need to be included in the next draft of the revised standard. We will take this into consideration. The COC Working Group will discuss this at their next meeting in March and adjustments to the draft standard will be made before the second public consultation. 3. The examples provided would not typically be considered ecoregions. We will take this into consideration for the next draft of the revised standard. 4. For the cross-site sharing, what is used as definition for ecoregion. WWF ecoregions, a broader definition, user defined? A definition and reference will need to be included in the next draft of the revised standard. We will take this into consideration at the COC Working Group Meeting in March. 5. Can the cross site sharing be applied to the % system too? The Cross-site credit sharing pilot specifically evaluated the risks and benefits of shared credit accounts in the context of the credit system. Therefore the study did not include a review or evaluation of shared percentage systems between multi-sites. Stakeholders who want FSC to conduct a similar study and pilot project for the percentage system must convey this message to FSC International. 6. Is it possible to share credit from site in multi site certification from different country? The current proposed draft requirements would only allow multi-site certificates to share credit accounts when all the sites are located in the same country. CLARIFICATION OF CREDIT SYSTEM 1. 5 years or remaining time left in current certificate. I don't think that credits should extend beyond current length of a company's certification. But there could be an allowance for rollover if the company chooses to go through a reassessment. The credit accounts would continue to roll over and would not last just until the length of the current certificate. 2. With the 5 years for the credit, could we be able to do it retroactively at the approval of the new standard. I.E could I use the credit of 2012 in 2016? No, credits that have already expired in the past would not be able to retroactively be brought back into the credit account. This clause would only apply moving forward. 6 of 8
7 3. With and additional credit accounts for each component is there a phase in date? I have concerns that FSC CW products sourced into a credit account currently do not have market availability to be credit eligible. The current draft requirement does not include a plan for a phase in approach to The draft credit system requirements clarify that separate credit accounts for each component are required when the components are visually distinguished by the naked eye and the inputs are made of different quality. LABELING THRESHOLD IN PERCENTAGE SYSTEM OTHER: 1. Will this % wording within the thresholds only come into play AFTER the 50% threshold goes up to 70%? Yes, the threshold will not change until the standard has become effective and Certificate Holders have transitioned to the new standard. The advice note for reduced labelling threshold of 50% for chip and fibre based products (ADVICE ) is no longer effective as of 31 December So any percent in paper product recycled 70 % and up will be FSC Mix or FSC 100% recycle? The change in the status of pre-consumer reclaimed paper fiber to a claim-contributing input will mean that FSC Recycled paper products produced under a percentage system will always be FSC Recycled 100%. The inputs into an FSC Recycled paper product can only be pre-consumer and post-consumer reclaimed materials, and as both inputs are considered claim-contributing inputs, the FSC claim will be FSC Recycled 100%. FSC Recycled wood products made under a percentage system will still have varying percentages in the FSC Recycled XX% claim as pre-consumer reclaimed wood is not going to be a claim-contributing input. However, the proposed change would mean that labelling threshold for FSC Recycled products would be reduced from 85% to 70%. 1. Isn t their usually a year from approval to effective date for FSC standards? AND Will there be a one year transition period to adhere to the new standard? If you have your annual audit in January 2016, will there be enough time for cert holders to meet the criteria? 7 of 8
8 FSC is going to discuss the implementation of the transition period with Certification Bodies in the first week of March. A specific standard interpretation on this will be published soon after this meeting. 2. Building construction projects going for LEED certifications [version 2009] targeting MR credit 6/7 Certified Wood [FSC] - there is still confusion as to who needs to have FSC-COC certification. Is it accurate, in aligning with FSC-COC requirement, that any entity along the construction chain modifies/fabricates the FSC product will need to have the certification? FSC US has worked with the USGBC to align the requirements for chain of custody with the requirements for contributing to LEED credits. Currently, FSC and LEED both require chain of custody certification for all companies in the supply chain that have legal ownership of FSC certified products and wish to pass on the FSC claim to customers through sales documents. This includes all manufacturers, distributors and offsite fabricators such as cabinetmakers and millworkers who sell wood products into a LEED project. However, there is one exception to this, LEED does not require chain of custody certification for companies in the supply chain that do not manufacturer products offsite and ONLY install FSC-certified materials onsite (such as flooring and furniture installers). 3. Why FSC does not require to verify the validity of supplier s certificate every 12 months? That would be simpler than "check for any change"? 12 months period is too long and this could create significant financial and reputational risk for certificate holders (e.g. a company is not informed about a suspension of a supplier s certificate and continues to use raw materials received from this supplier in the FSC certified production. Several months later, the company discovers that a considerable amount of products shall be treated as non-conforming products). The OCP system is designed to support companies conformity with this requirement and might represent and easier and safer solution than simply requiring the verification of the validity of supplier s certificate every 12 months. 4. Is the timeline for transition to the new standard the same for Canadian Certificates? The FSC Chain of Custody Standard is a global standard and therefore will become effective on the same date for all Certificate Holders globally. 8 of 8
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