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FSC Controlled WoodFSC’s Unique and Challenging Approach to Due Diligence
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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:
- Gather and maintain basic information about the source of non-certified inputs to your CoC System
- Periodically evaluate the likelihood (i.e. risk) of ethically unacceptable material in your supply chain
- 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 basic documentation and record-keeping requirements, which are not 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.
Back to the Source
FSC’s Controlled Wood webpage has links to the standard and other official guidance for implementation.
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