A quick glance at the commentary on this site will reveal that our most common topic, by far, has been calling attention to dumb things that the FSC does. We take no pleasure in pointing this out. The Forest Stewardship Council is a fine organization dedicated to a good and positive mission: the conservation and protection of the world’s forests. MixedWood is proud to part of this mission. As an organization, however, FSC has had a very hard time remembering this mission. It continues to get distracted and do more and more and more. And make dumb decisions. Which leads us to the topic for today. One of the worst examples we’ve addressed in our eleven years of commentary.
Making CoC a “social” standard
When FSC took the important, and very ill-considered, decision to change its Chain of Custody standard by incorporating specific, auditable requirements that have nothing to do with Chain of Custody, we called it a mistake. We have always asserted that Chain of Custody standards should be simple and easy. They should provide a clear and verifiable link between the wood products from certified forests and the commercial product marketplace – and nothing more. The magic of product certification comes from linking the vast power of commercial markets to sustainable/responsible commodity production. FSC is dedicated to promoting responsible forest management, and that is where its focus should remain. When the CoC standards were stretched to include other indicators, FSC began trying to reform the whole commercial marketplace. This was a serious mistake.
To their credit, FSC have taken actions in the last couple of years to make the Core Labor Requirements (CLR) relatively practical and painless to implement in low-risk countries with strong traditions of legal compliance. Here in the United States, certified companies can meet the FSC CLR’s by completing and filing some simple and straightforward paperwork at their annual audit. It is an annoying and unnecessary exercise, but relatively easy – as it should be. As of last month, most certified companies have found ways to conform, and we hoped that we could focus our attention elsewhere. As it turns out, we were wrong. FSC staff decided to screw things up again.
A Brick Wall Across the Railroad Track
Early last month, FSC International (FSC-IC) staff released a series of new Advice Notes designed to radically change the implementation process for the Core Labor Requirements. Advice Notes are intended to provide clarification and guidance to the community. But they are too often used to simply change the requirements.
In this case, it seems clear that FSC-IC staff had concluded that the FSC CLR’s were simply not hard enough to implement. So they made them harder. Instead of requiring certified companies to complete and file a self-assessment against the CLR, covering their own company operations and staff; they will now be required to assess and document their contract service providers (Outsourcers) as well. The only reason for this change seems to be a desire to make the standard harder. Because a harder standard is – apparently – ‘more credible’. A seriously dumb idea that seems to motivate so many of these decisions.
The specific, new requirements are found in 2 updated Directive documents:
The details (as usual) are challenging to understand. But the bottom line is that most CoC certified companies will be required to do quite a lot of work, for no practical purpose at all. And most of that work will need to be audited by their Certification Bodies.
It is objectively clear that the implementation of these new requirements will be confusing, challenging, and time consuming. So you might assume that FSC would have provided a reasonable transition period. Unfortunately, they did not. The official deadline for implementation is July 1 2023. That’s right – tomorrow.
As of today, FSC reports 55,944 CoC certificates around the world. We think it is reasonable to compare this to a freight train. Something enormous and with a lot of inertia. As of tomorrow, almost all of these certificates will be in violation of the FSC requirements. A brick wall. What happens next? We’ll have to wait and see.