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FSC response to TFT: Ensuring a Strong Chain-of-Custody System

This is the Forest Stewardship Council’s response to a recent commentary carried on The following represents the views of the FSC, not necessarily On August 8. 2013 Poynton responded to comments posted on his op-ed.

Recently, the Director of The Forest Trust (TFT) shared his opinion with Mongabay readers criticizing Chain-of-Custody systems in general, and the Forest Stewardship Council’s (FSC) system in particular. The impetus for the critique was a joint statement issued by FSC and PEFC rejecting an ISO proposal for a new Chain of Custody standard for forest products.

As a multi-stakeholder certification system strengthened by broad participation and dialogue, FSC welcomes comments from all stakeholders, including TFT. We appreciate the work TFT does to encourage forest managers to improve their practices and achieve FSC certification.

To be credible, a forest certification system must ensure there is a verified connection between responsibly managed forests and the certified products sold to end users. If the truthfulness of a claim cannot be verified, the certification is meaningless. This is the rationale behind the FSC’s Chain-of-Custody certification system.

FSC operates a robust, credible and impactful forest certification system across the globe. From the final consumer, through retailers, distributors, manufacturers, and mills to the forests of origin, FSC translates market demand into improved social and environmental outcomes.

Thousands of companies, more than 180 million hectares of forest, and the people and species that depend on these forests, benefit in ways large and small from the FSC system. All of it depends on the integrity of the FSC Chain-of-Custody system.

Our business model is designed to ensure this integrity and drive improved forest management around the world.

While FSC is proud of what our members, promoters and partners, forest managers and the many actors along certified supply chains have accomplished to date, we recognize there is still work ahead. We do not look at our success over the last 20 years with any complacency. Quite to the contrary, FSC constantly explores and spearheads new concepts and instruments enabling us to strengthen our system.

One recent and exciting endeavor is the establishment of an Online Claims Platform (OCP). The OCP, targeted to go live as a beta version in October this year, will provide better oversight of the Chain-of-Custody system and improve the accuracy of FSC claims being made. By uploading information about product transactions, the OCP will give companies a new secure tool to simplify reporting and audits, verify country of harvest and develop metrics related to the trade of FSC products, all of which will support compliance with EU Timber Regulations and the Lacey Act. The OCP will also show if a certified company is actually making FSC claims or not, so in the future it will be known in real time if and to what extent they are trading FSC certified products.

Whether certified companies do or do not trade much FSC certified product, FSC requires its certificate holders to maintain their Chain-of-Custody systems to ensure that certified and non-certified product is not confused or unduly combined. We have targeted programs dealing with this in countries such as China and India, where we undertake additional oversight of supply chains, including systematic reviews of Chain-of-Custody reports, verifying high-risk supply chains, trademark use investigations and, more recently, fiber testing.

Further to this, FSC enforces strict rules to identify potential conflicts of interests for certification bodies to ensure the impartiality of certification decisions. Conflicts arising from relationships – whether based on ownership, governance, management, personnel, shared resources, finances, contracts, or marketing – need to be demonstrably eliminated or minimized. This has been an area we have focused on in China over the past five years and has involved more oversight assessments performed by Accreditation Services International (ASI), the FSC’s global accreditation body, than in any other country. ASI takes strong action when certification bodies do not perform correctly, which regularly results in suspensions of certification bodies’ accreditation status.

In any global system, there may be bad actors who try to cheat and bend the rules of the system. In this respect, FSC is no different. While the vast majority of our certificate holders are committed to our mission, some may try to use FSC for greenwashing or look for ways of meeting FSC market demand by trying to get around the rules. It is for this reason that we continuously build and revise oversight features for the Chain-of-Custody system and we use effective mechanisms to stop companies from greenwashing where they are involved in controversial activities, through our Policy for the Association of Organizations with FSC.

Importantly, the FSC system gains unique strength from an engaged community of stakeholders, including our members and certified companies. All stakeholders can openly access comprehensive information on certified companies through FSC’s global certificate database ( and can engage in policy processes, innovative new systems development and our complaints and dispute mechanisms, to ensure FSC remains the benchmark as the most credible and effective, transparent and participatory forest certification scheme.

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