The current exemption applying to the use of non-controlled co-products in the FSC system is about to expire.
As of 1 January 2013, co-products may thus no longer be used as input for manufacturing FSC certified products without assuring their origin and assessing the risk of non-conformance with the FSC Controlled Wood criteria for acceptable sources. However, the new requirements for assuring the origin of co-products still constitute an exemption from the normal controlled wood requirements.
The co-products exemption was established due to the difficulty of obtaining information about the source of origin for this type of material.
Co-products are commercially traded products generated through the production of primary products, such as chips and sawdust from sawmills.
The deadline is specified in Advice Note 17 contained in the FSC Controlled Wood Directive (FSC-DIR-40-005), which also stipulates how certificate holders need to handle co-products following the date of expiry.
How to meet the new obligations
To comply with the FSC requirements in 2013, if you are using co-products you need to: firstly, obtain information about the source of origin; secondly, assign low or unspecified risk to the products; and thirdly, implement a field verification programme in case of unspecified risk.
One way of ascertaining the origin of the co-product is to obtain proof of purchase from the forest of origin. However, this is often difficult or impossible for co-products, which is why FSC has provided an alternative option. This option now constitutes the only difference pertaining to co-products compared to other products used as controlled wood.
The other option is to enter a legally effective, written agreement with your supplier that includes a statement on the sources of origin.
The agreement must declare the co-products’ geographical origin - countries, regions, or forest management units depending on what level is relevant for your further risk assessment. It must also include a commitment to support you in collecting information needed to identify the forest of origin, in cases where the sourcing area implies unspecified risk.
If you opt for a supplier agreement, you need to conduct a “plausibility check” to verify that the information is realistic, covering the following criteria:
i) Is the supplied timber species commercially harvested in the declared district (and carries a CITES certificate if required)?
ii) Is the type and quality of the supplied material commercially available from the declared district?
iii) Are the distance and means of transportation to the company (or to the supplier site in case the supplier is purchasing co-product inputs) consistent with the declared district and economically viable?
In making these judgements, the precautionary approach must be followed.
Assessing and handling risk
The procedure for handling co-products has to follow the normal controlled wood procedures in all other aspects, which means that you need to assign either low or specified risk needs to the products, based on their district of origin.
If the co-products are found to originate in areas of unspecified risk, you are required to conduct field audits as for all other controlled wood material.
Tightening the nuts and bolts of the FSC system
“The new requirements demand increased commitment by certificate holders using co-products”, says Roman Polyachenko, chain of custody expert at NEPCon. “Some will face major challenges under the new requirements, but for those who are sourcing from low-risk areas, there is only a limited amount of additional work involved. In most cases, the simplest solution for them is to enter into agreements with their suppliers including plausible declarations of product origin and to conduct the plausibility check”.
According to Mr Polyachenko, the change is well-justified: “This change is an integral and necessary part of FSC’s efforts to align with the EU Timber Regulation. The main challenges apply to those who are sourcing from high-risk areas – and in those cases, it is crucial to put in more effort to exclude illegal and other non-acceptable timber from FSC products. This is important not only for the alignment process, but also for securing the credibility of the FSC system. No part of the FSC system should be left open for unacceptable timber”.