MixedWood LLC

Controlled Wood Club Members Area

Support for Implementation of FSC Controlled Wood

Welcome to the MixedWood Controlled Wood Club.  This site is designed to provide a broad and comprehensive package of reference materials, guidance, information, and support for our client companies who are certified to, and actively implementing the Forest Stewardship Council’s requirements for Due Diligence, found in FSC-STD-40-005 v.3-1.

The material here is regularly reviewed and updated by MixedWood staff, to ensure effective and ongoing conformance to FSC program requirements.  User feedback is vital to keeping this material current and useful.  Please contact us promptly if you encounter problems, find omissions or errors, or are in need of specific help or interpretation.  We will respond promptly and personally.

Comments, updates, & other feedback:  dan@mxwood.com

A business note:  this collection of materials, as well as all of the original documents included, are copyrighted by MixedWood LLC and provided for use solely by our clients within the terms of our contractual relationship.

FSC Controlled Wood:
An Overview & Primer

The FSC Controlled Wood program is not particularly unique.  All three of the major Forest Product Chain of Custody (CoC) programs have similar and parallel requirements.  MixedWood summarized them in our blog several years ago.  Their function and purpose consists of three basic steps:

  1. Gather and maintain basic information about the source of non-certified inputs to your CoC System
  2. Periodically evaluate the likelihood (i.e. risk) of ethically unacceptable material in your supply chain
  3. Segregate and isolate material that does not meet your eligibility standards for mixing in the CoC system

Taken together, a system following these steps allows a company to demonstrate that they have exercised “Due Diligence” in avoiding unethical or illegal inputs.  We call these programs Due Diligence Systems – abbreviated DDS.

Historically, PEFC & SFI have taken a simple and flexible approach to this process.  Both have significantly confused the issue, recently, by releasing overly-complex and confusing new standard language.  But both still focus their efforts on identifying illegal sources and take an open and non-prescriptive approach to the risk assessment process (Step Two above).

FSC, of course, likes to be different. Their program is based on ethical standards that go beyond legality, and – importantly – identify a series of rather complex and convoluted expectations for demonstrating compliance.

FSC’s current Controlled Wood standard embraces the internationally-recognized format for Due Diligence – driven largely by timber legality legislation in the US, the EU, & elsewhere and an indispensable framework for responsible timber procurement worldwide.

This framework is based on three steps:


Step One

Information Gathering

This includes the basic documentation and record-keeping requirements which are not be challenging for companies who keep good track of their supply chains.  Also included are some management system requirements, including annual internal audits and reviews.


Step Two

Risk Assessment

This topic challenged the FSC for many years but was stabilized in 2018 with the release and approval of National Risk Assessments (NRA) for the United States and Canada.  These national-level documents define and document the official FSC position on a wide range of topics related to sustainability and sourcing risk.  The conclusions of the US and Canada NRAs form the basis of the implementation and management challenges addressed on this website.


Step Three

Risk Mitigation

The identification of sourcing risk that is not low but rather “Specified” leads to a series of additional requirements for Controlled Wood companies.  Collectively termed “Control Measures”, a series of performance requirements are created that need to be interpreted, adapted, and implemented by certified companies.  These Control Measures are the principal reason that MixedWood organized our Controlled Wood Club.


MixedWood Due Diligence & Mitigation

MixedWood has created a step-by-step outline to help guide your business through the process.

Back to the Source

FSC’s Controlled Wood webpage has more information, links to the standard, and other guidance for implementation.

National Risk Assessments:
Introduction & Overview

National Risk Assessment: United States

The National Risk Assessment for the Conterminous United States (US-NRA) was formally published in April 2019, and implementation became mandatory for CW companies in October.  To date, implementation appears to have gone reasonably well, with few disruptions in the first year of audits.  We expected challenges in 2020, but this seems to have been muted by the shift to remote auditing during the pandemic year.  We continue to expect feedback from the ongoing audit cycles.

National Risk Assessment: Canada

The National Risk Assessment for Canada (Canada-NRA) was formally published on June 26, 2018.  Delays in implementation, including an important, late update meant that full implementation did not begin until early 2020.

While the Canada-NRA is designed to meet the same requirements and serve the same purpose, its style and detail differ considerably from the US-NRA – presenting significant challenges for companies sourcing wood in the border regions.

MixedWood has established a collaboration agreement with Abies Consultants of Edmundston, NB to support our clientele who source Canadian wood.  Please contact us directly for more information about these services.