Earlier this year, I wrote about changes to the PEFC Chain of Custody standard – driven largely by new wood-product legality legislation that went into force in the European Union last year. The new regulations (EUTR) really grabbed the attention of all the policy folks in Europe – especially the folks who work for PEFC and FSC. Their response is likely to make life more complicated for the rest of us.
I worked on two projects last month which allowed me to get “down and dirty” with the new PEFC standard. I thought I would share some of my observations and ideas.
PEFC ST 2002:2013 – What’s New?
The overall organization of the 2013 standard is similar to the earlier version. This isn’t surprising, as the “old version” dates only from 2010. The organizational format remains as before, and much of the basic language – relating specifically to Chain of Custody – is unchanged. First comes material input (Section 4), followed by sales (Section 6), claims accounting (Section 7), management system requirements (Section 8), and social elements (section 9). The big difference is in the section I skipped – Section 5: Due Diligence.
Due Diligence is not a new concept for PEFC. It was a requirement in earlier versions of the standard, but its applicability was limited to the input of non-certified materials to be used in percentage- or credit-based claims. It required the avoidance of “controversial sourcing” when buying this kind of raw materials. For companies who keep their certified material separated, it could be safely ignored, and generally was. For the rest, there was a simple and clear requirement to collect and file “self-declarations” from your supplier – effectively passing responsibility up the supply chain.
In the 2013 version, PEFC has placed Due Diligence System (DDS) requirements front and center. The new Section 5 is the longest and most complex part of the standard. It includes a confusing set of overlapping requirements designed to mirror the legal standards published by the EUTR. They seem to have achieved this, but at the cost of making the standard much more challenging to understand.
The Good News
I am concerned that many US companies who currently hold PEFC certificates are likely to find the 2013 standard too much to swallow. The simple solution will be to drop their certificate. In most cases, however, this will be a mistake. Assuming that you have a business case for your PEFC certificate today (if not, why do you hold a certificate?), I recommend that you do not let the 2013 update scare you away. Here’s a couple reason’s why:
a) You can define your own scope. The scope of your PEFC system does not have to include all of your activities and products.
b) Section 5 DDS can be managed. For the vast majority of current CoC companies, doing business in the US and Canada, a DDS can be designed that is short, simple, and painless. It can be folded right into your existing procurement system and maintained with a couple hours work, once a year.
The trick to all this is simple: Don’t let the complexity of the standard tempt you into putting complexity into your business. There’s always a simpler way. If you haven’t found it yet, keep looking.