FSC Directive on Chain of
Custody Certification
FSC-DIR-40-004 EN
Last Updated: 07 October 2015

Title:FSC Directive on Chain of Custody Certification

Document reference code:

FSC-DIR-40-004 EN

Scope:

International

Contact for comments:

FSC International Center- Policy and Standards Unit Charles-de-Gaulle-Str. 553113 Bonn, Germany+49-(0)228-36766-0+49-(0)228-36766-30

policy.standards@fsc.org© 2015 Forest Stewardship Council, A.C. All rights reserved.
FSC® F000100

No part of this work covered by the publisher’s copyright may be reproduced or copied inany form or by any means (graphic, electronic or mechanical, including photocopying,recording, recording taping, or information retrieval systems) without the written permissionof the publisher.
Printed copies are uncontrolled and for reference only. Please refer to the electronic copy on
the FSC website (ic.fsc.org) to ensure you are referring to the latest version.

The Forest Stewardship Council® (FSC) is an independent, not for profit, non-governmentorganization established to support environmentally appropriate, socially beneficial, andeconomically viable management of the world's forests.
FSC’s vision is that the world’s forests meet the social, ecological, and economic rights andneeds of the present generation without compromising those of future generations.

FSC-DIR-40-004 COC DIRECTIVE2015– 2 of 19 –

CONTENTS
A

Scope

B

Effective date

C

References

D

FSC normative documents replaced by this DirectiveE

Terms and definitions

Part 1 General Issues
Part 2 FSC Advices

ADVICE 40-004-01

FSC Certified COC Contractors

ADVICE 40-004-02

After the certificate issuance, when the company products will be
eligible to carry the FSC logo?

ADVICE 40-004-03

Reduced labelling threshold of 50% for chip and fibre based
products

ADVICE 40-004-04

Use of uncontrolled co-products (Withdrawn)

ADVICE 40-004-05

Identification of FSC claims on sales and delivery documents

ADVICE 40-004-06

Which components of a product need to be certified?

ADVICE 40-004-07
ADVICE 40-004-08

Sale of FSC certified products through non-FSC certified auction
entities
Non-conforming product

ADVICE 40-004-09

Minor components (Withdrawn)

ADVICE 40-004-10

Access to information required by timber legality legislations

ADVICE 40-004-11

Trade and customs laws

ADVICE 40-004-12

Pre-consumer reclaimed wood compliance with the EUTR

ADVICE 40-004-13

Classification of pre-consumer reclaimed paper as equivalent to
FSC certified and post-consumer reclaimed materials

FSC-DIR-40-004 COC DIRECTIVE2015– 3 of 19 –Foreword
FSC received various comments from Certification Bodies and stakeholders
requesting a reduction in the number of normative documents to make thedocumented certification system more comprehensible. FSC therefore combined all
previous Advice Notes into single documents which are called “directive”. A directive
includes all advices issued in relation to a single standard. The relation to a standard
is reflected in the document code. Where new interpretation is approved, these will
be added to the directive and the revised document will be reissued.
The intention of this document is to standardize understanding and implementation ofrequirements by FSC accredited certification bodies and certificate holders.
This document will be revised as required. The content of the directive will beincorporated into the related standards in each major review as feasible.
Changes and amendments to the directive will be announced to the FSC Network
immediately.
Note on use of this directive
All aspects of this document are considered to be normative, including the scope,
effective date, references, terms and definitions, tables and annexes, unlessotherwise stated.

FSC-DIR-40-004 COC DIRECTIVE2015– 4 of 19 –

A

Scope

This document provides FSC’s formal interpretation of the requirements included in
FSC-STD-40-004.

B

Effective date

The effective date is specified for each advice separately.
C

References

The following referenced documents are indispensable for the application of thisdocument. For undated references, the latest edition of the referenced document(including any amendments) applies.
FSC-STD-40-004 Standard for Chain of Custody Certification
D

FSC normative documents replaced by this Directive

FSC-ADV-40-004 V2-0 Expiry of transitory requirements specified by FSC-ADV-40004.
FSC-ADV-40-017 V1-1 FSC Certified CoC Contractors
FSC-GUI-20-200 FSC Guidelines for Certification Bodies (Part 3)

E

Terms and definitions

Terms and definitions are provided in FSC-STD-01-002 FSC glossary of terms and in
FSC-STD-40-004 Standard for Chain of Custody Certification. Further advice-related
definitions may be provided in the context of each advice.

FSC-DIR-40-004 COC DIRECTIVE2015– 5 of 19 –Part 1 General Issues
1

The FSC Directive is providing certification bodies and other stakeholders
with clear advices on the implementation of FSC's international policies andstandards. A directive is designed to provide formal advice in relation to asingle specific issue or question raised with the FSC International Center. Alladvices on a series of issues related to a specific FSC international policy or
standard are collected in one document to improve accessibility ofinterpretations for certification bodies, certificate holders and interested
parties.

2

If a certification body is in doubt about the correct implementation of an FSC
policy or standard, the certification body must request clarification from the
FSC Policy and Standards Unit. If required, such clarification will be provided
in the form of a new directive.

3

Prior to the finalisation of an advice, a certification body may make its own
decision in relation to a question for which clarification has been sought. In
such a case, responsibility for the consequences of the decision shall rest
exclusively with the certification body concerned. Formal advice subsequently
provided by the FSC International Center will be applicable retrospectively.

4

The advices provided in this document represent the formal position of the
FSC International Center unless and until it is superseded by the approval ofa more recent policy, standard, or advice. In such cases the requirements
specified in the more recent document shall take precedence.

5

Certification bodies are required to comply with the most recent formal
advices, and the FSC Accreditation Business Unit will base its evaluations
and issue of corrective actions on these.

6

Finalised advices are approved by the Head of the Unit of the Policy andStandards Unit or the FSC Director General. If a certification body wishes tocontest the advice provided it may do so by requesting a formal review anddecision by the FSC Policy and Standard Committee. Until and unless such a
review and decision has been finalised, the certification body shall continue tocomply with the position of the FSC International Center.

7

Directives are under continual review and may be revised or withdrawn in
response to new information, experience or changing circumstances, forexample by the development of new policies or standards approved by the
FSC Board of Directors.

FSC-DIR-40-004 COC DIRECTIVE2015– 6 of 19 –Part 2 FSC Advices
ADVICE-40-004-01

FSC certified CoC contractors

Normative reference
Effective date

FSC-STD-40-004 V2-0 Section 12
FSC certified CoC organizations may apply this advice from 9th February2010 and, if applicable, shall be assessed for compliance from 1st January
2011 onwards.
The terms defined in FSC-STD-20-011 and FSC-STD-40-004 apply. The
following terms are introduced by this Advice Note and are put in italics
throughout the document:

Terms & definitions

Contracting organization: Individual, company or other legal entity
contracting a contractor for the production or processing of an FSC certified
product under an outsourcing agreement.
NOTE: The contracting organization may or may not be an FSC certified
CoC organization. Part C of this Advice Note is structured according to the
FSC certified status of the contracting organization (see Part C, Table 1).
Contractor: Individual, company or other legal entity contracted by acontracting organization for the production or processing of an FSC certified
product under an outsourcing agreement.
NOTE: In the context of this Advice Note, the contractor is an FSC certified
organization (see Part C, Table 1).
FSC certified CoC organization: Individual, company or other legal entity
holding a valid FSC Chain of Custody certificate which confirms thatappropriate procedures are in place for the production, processing or tradeof a specific product – or that FSC certified CoC contractors are used forthis purpose – that allow the organization to sell, provide or promote theproduct with FSC claims.
Outsourcing agreement: A written agreement between a contracting
organization and a contractor about the service of producing or processing
an FSC certified product or material, where the contracting organization
retains control of and responsibility for the purchasing of input material fromthe (billing) supplier and for the sale of the output product to the customer.
Input material may be shipped from the contracting organization or from the(delivering) supplier to the contractor and the output product may bereturned or shipped from the contractor to the contracting organization or tothe contracting organization’s customer.
Supplier (billing): FSC certified CoC organization selling material with FSC
claims to the contracting organization.

Background

Supplier (delivering): FSC certified CoC organization delivering the material
to the contractor and selling the material with FSC claims to the billing
supplier or to the contracting organization.
This directive deals with the implications for FSC certified CoC
organizations, either functioning as or making use of FSC certified CoC
contractors. In particular, clarification is provided on the following issues:under which conditions contract work for an FSC certified product canbe provided for non-FSC certified CoC contracting organizations;

what the benefits and implications are for FSC certified CoC contracting
organizations that use FSC certified CoC contractors.

The FSC Standard for Chain of Custody Certification (FSC-STD-40-004)
requires organizations that take legal ownership of materials and want to

FSC-DIR-40-004 COC DIRECTIVE2015– 7 of 19 –

maintain or change the FSC claim associated with the output product tohave FSC Chain of Custody certification.1 The standard further specifies
the requirements to follow for FSC certified CoC contracting organizations
in order to use non-FSC certified CoC contractors for this purpose.
The questions, however, what the implications are for an FSC certified CoC
contracting organization to use FSC certified CoC contractors, and whether
contract work for an FSC certified product could be provided also for nonFSC certified CoC contracting organizations were not consistently dealt within practice. In particular the latter question required some fundamental
judgement, as some certification bodies considered contract work for nonFSC certified CoC contracting organizations to be generally not in line withstandard requirements, while others found outsourcing arrangements where
the non-FSC certified CoC contracting organization would not obtainphysical possession of the input material to be acceptable under certain
additional stipulations.
This Advice Note follows the latter approach based on the judgement that
there would not be an increased risk associated with such outsourcing
arrangements for non-FSC certified products to be labelled and sold as
FSC certified, provided that additional safeguards were in place. The Advice
Note stipulates these safeguards and aims at providing the relevant
answers to the questions raised above.
AdviceTable 1: Outsourcing scenarios dealt with by this
Advice Note
Requirements
forSectionFSC certified status

Details

Contractor

Contracting
organization

1

Contractor

Providing contract work for
non-FSC certified CoC
organizations

FSC

non-FSC

2

Contracting
organization

Using FSC certified CoC
contractors

FSC

FSC

1

Providing contract work for non-FSC certified CoC
organizations – conditions for FSC certified CoC contractors
NOTE: This section applies for outsourcing arrangements where
the contractor is an FSC certified CoC organization and thecontracting organization is a non-FSC certified CoC organization.
Under this scenario, the contracting organization cannot sell the
product with an FSC claim to commercial customers. The
contracting organization may, however, use the FSC trademarks topromote the product towards final consumers as specified by FSCTMK-50-201.

Eligibility1

1.1

FSC certified CoC contractors are only eligible to provide FSC
certified products for non-FSC certified CoC contracting
organizations, if:

1.1.1

The input material for the contract work is shipped directly from thedelivering supplier(s) to the contractor, i.e. the contracting
organization does not obtain physical possession of the input
material.

1.1.2

The contractor is provided with a copy of the invoice(s) from thedelivering supplier(s) and, if not identical, from the billing

FSC-STD-40-004 V2-0, Section A

FSC-DIR-40-004 COC DIRECTIVE2015– 8 of 19 –

supplier(s) that include(s) information sufficient to link the invoice(s)and related transport documentation to each other.
NOTE: Information on prices can be blacked out.
1.1.3

The output product provided by the contractor is:a) a finished product;b) FSC labelled; andc) branded with the name, label or other identifying information of
the contracting organization.

Labelling
1.2

For each contract work, the contractor shall maintain control ofapplying the correct FSC label.

1.3

The contractor shall ensure that its license code is used in the FSC
label and submits the proof to its certification body for approval.

2

Using FSC certified CoC contractors – conditions for FSC
certified CoC contracting organizations
NOTE: This section applies for outsourcing scenarios where theboth the contractor and the contracting organization are FSC
certified CoC organizations. Under this scenario, the product does
not have to be FSC labelled or a finished product.

Outsourcing agreement
2.1
2.1.1
2.1.2

2.1.3
2.2

The outsourcing agreement shall specify the following:that the contractor provides the service under his FSC Chain of
Custody system,that the contractor makes available relevant records anddocumentation to the contracting organization’s certification bodyupon request, andthat the contracting organization’s license code shall be used, if the
product shall be FSC labelled.
The outsourcing agreement and, if FSC certified CoC contractors
are used for specific processes exclusively, the contracting
organization’s control system for the outsourced process do notneed to cover the following requirements stipulated by FSC-STD40-004:– clauses 12.1.1 c), second sentence, and 12.1.1 d);– clause 12.2.1;– clauses 12.5.1, 12.6.1, and 12.7.1
NOTE: FSC certified CoC contractors may use their own
subcontractors in accordance with FSC-STD-40-004,
section 12.

Supplier validation
2.3

The contracting organization shall apply the provisions for ‘suppliervalidation’ as specified by FSC-STD-40-004 also to the contractor.

Labelling
2.4

The contracting organization shall maintain control andresponsibility of the correct FSC label being applied, if product

FSC-DIR-40-004 COC DIRECTIVE2015– 9 of 19 –labelling is part of the outsourced processing.
2.5

The contracting organization shall ensure that its license code isused in the FSC label and shall submit the proof to its certificationbody for approval.

Auditing
2.6

FSC certified CoC contractors are exempted from a potential
inspection by the contracting organization’s certification body, if theoutsourced process is covered by the scope of the contractor’scertificate.
NOTE: The contractor is subject to evaluation and monitoring by
its own certification body.

ADVICE-40-004-02

After the certificate issuance, when the company products will
be eligible to carry the FSC logo?

Normative reference
Effective date
Background

FSC-STD-40-004 V2-0 Clause 10.1.1
March 2005

AdviceA forest product manufacture is often a continuous process. At the timethat a certificate is issued there are likely to be products undergoing
manufacture, products that have been manufactured but not yet shipped,
and products that have been shipped but not yet put on sale by the buyer.
Which of these products are eligible to carry the FSC Logo?
1

The scope of the certificate defines the point at which the certified
chain of custody starts, and the point at which it finishes. The chainof custody certificate provides a credible guarantee of compliancewith the requirements of the specified standards between thesepoints. This guarantee is valid from the time that the certificate isissued. Any product which is within the defined scope of thecertificate at the time the certificate is issued may be considered tocomply with the requirements of the applicable standard(s). Suchproducts may be eligible for sale as 'FSC-certified' products.
Products which have already left the scope of the certificate at thetime the certificate is issued cannot be considered to be certified.

2

Normally this will mean that products that have already been sold,or shipped, prior to the issue of a certificate may not be describedas certified, and are not eligible to carry the FSC Logo.

3

Clearly a company cannot issue an invoice describing products ascertified prior to the issue of chain of custody certificate. Products
sold without such an invoice cannot be described as certified, andare not eligible to carry the FSC Logo.

4

In the case of joint forest management and chain of custodycertification, application of this guideline means that timber that had
been felled prior to the issue of a certificate, but which has not yet
been sold by the forest management enterprise may be sold ascertified.

5

Equivalent considerations apply when a certificate is withdrawn or
expires. Products which left the chain of custody whilst thecertificate was valid were certified, and remain certified even after
the certificate has been withdrawn. Products which have not yet
left the chain of custody at the time the certificate is withdrawn will
not be certified.

FSC-DIR-40-004 COC DIRECTIVE
2015– 10 of 19 –

ADVICE-40-004-03

Reduced labelling threshold of 50% for chip and fibre based
products

Normative reference

FSC-STD-40-004 V2-0, Clause 11.2.1a and 11.2.2

Effective date

14 February 2011

Terms & definitions

Company: the legal entity that must comply with FSC-STD-40-004 V2-0
which is either the certificate holder or an applicant for certification.

Background

When the new Chain of Custody standard “FSC-STD-40-004 (Version 2):
FSC Standard for Chain of Custody Certification” was approved in
November 2007, the following previously established exemption wasmaintained by means of an Advice Note:
A labeling threshold of 50% for chip and fibre based products under apercentage (or transfer) system.
NOTE: The exemption detailed in this advice is specifically related to theeligibility for labelling FSC products and not to the eligibility of producing or
selling products with an FSC claim on invoices.

Advice1

FSC certificate holders may request authorization from theircertification bodies to continue labelling chip and fibre products
based on a reduced labelling threshold of 50% until 31 December
2015.

2

Authorization shall only be granted for those product groups withchip and fibre components registered as being commercially
produced based on a labelling threshold of 50% before 01 April
2011.

3

Certificate holders operating a transfer system that have notregistered their product groups can also label products based on alabelling threshold of 50% in case they are able to demonstrate totheir Certification Body that the material they receive has alreadybeen registered by a previous company or the material wasreceived with an FSC on-product label.
a) In the first case, sales and delivery documents issued by the
supplier shall include the additional claim “registered” (e.g. “FSC
Mixed 50% registered”);b) In the second case, the certificate holder shall retain evidence
that the product was received with an on-product FSC label (e.g.
packaging or product sample).

4

Certificate holders interested in the product registration shall submit
the following documentation to their Certification Body until 31
March 2011:a) A list of product groups with products labelled on the basis of a
50% threshold.
b) Copies of sales invoices for the registered products in each listed
product group as evidence that they have been commercially
produced.

5

Certification bodies shall upload the approved registration form into
the FSC database following the procedures to make it publicly
available. No new product groups can be added to this list after 31
March 2011.
NOTE: The registration form may be translated and uploaded in thelanguage used by the company as long as the product groupnames are also included in English as in the company’s FSC
product group list.

FSC-DIR-40-004 COC DIRECTIVE2015– 11 of 19 –

6

Product groups registered by certification bodies according to thisadvice shall be in compliance with a labelling threshold of 70% as of
01 January 2016.

NOTE: Companies that do not comply with the requirements of this advice
are not eligible to label FSC products based on a 50% threshold asof 01 April 2011, and therefore shall apply a labelling threshold of
70% from this date onwards.

ADVICE-40-004-04

Use of uncontrolled co-products

StatusWithdrawn

ADVICE-40-004-05

Identification of FSC claims on sales and delivery documents

Normative reference

FSC-STD-40-004 V2-0, Clause 6.1

Effective date

14 February 2011

Terms & definitions

N/A

Background

The FSC Chain of Custody standard requires certificate holders to identify
FSC certified products on sales and delivery documentation in order to passon the FSC claim of certified products to subsequent customers. However,
several organizations have limitations with providing complete FSC claims
that are required due to space constraints in these documents.

AdviceWhen the certificate holder has demonstrated it is not able to include therequired FSC claim as specified in the FSC Chain of Custody standard insales and delivery documents due to space constraints, through an
exception, the certification body can approve the required information to beprovided through supplementary evidence (e.g. supplementary letters, a linkto the own company’s webpage with verifiable product information). This
practice is only acceptable when the certification body is satisfied that the
supplementary method proposed by the company complies with thefollowing criteria:a) There is no risk that the customer will misinterpret which products
are or are not FSC certified in the document;b) The sales and delivery documents contain visible andunderstandable information so that the customer is aware that thefull FSC claim is provided through supplementary evidence;c) In cases where the sales and delivery documents contain multiple
products with different FSC Claims, a clear identification for eachproduct shall be included to cross-reference it with the associated
FSC claim provided in the supplementary evidence.

ADVICE-40-004-06

Which components of a product need to be certified?

Normative reference

FSC-STD-50-001 V1-2, Clause 2.4

Effective date

30 March 2011

Terms & definitions

Eligible input: Virgin and reclaimed material input that is eligible to enter a
specific FSC product group depending on its material category (e.g. FSC
Pure, FSC Controlled Wood, etc.).
Inserts: Enclosed advertising in a periodical (e.g. newspaper, magazine)that is distributed through the carrier publication and is a clearly
distinguishable element in relation to the other pages of the periodical (e.g.

FSC-DIR-40-004 COC DIRECTIVE2015– 12 of 19 –

Background

Advicedifferent paper, size, etc.). For example, inserts may take the form of returncards, coupons, recipe booklets, forms, booklets, brochures, gift premiums,
reply envelopes, etc.
Clause 2.4 of FSC-STD-50-001 Requirements for the use of FSC
Trademarks by Certificate Holders establishes that “The FSC label shall not
be used to make a partial claim about a product. Where permanent parts ofthe product (other than any packaging materials or non-forest basedmaterials) are not covered by FSC certification, the FSC label shall not be
used.”FSC receives repeated inquiries from different stakeholders in relation towhich components of a product are considered to be “permanent“, due tothe fact that these products can contain several forest-based elements thatare included in the product with secondary functions such as transportation,
protection, etc. This advice aims to clarify which of these components are
required to be certified and provides examples of practical implementation.
All components of a product which are made of or contain material
originating from forests that are incorporated into the product to fulfil its
function for the consumers’ specific need shall be certified. It represents
that all certified components of a product shall comply with the definition ofeligible input (e.g. FSC Pure, FSC Controlled Wood, etc.) and its quantities
in volume or weight shall count towards the calculation of FSC productcomposition determining its eligibility to carry the FSC label.
Forest-based components that have secondary functions in the product(e.g. for transportation, protection, etc.) don’t need to be certified unlessthey are added to the product with a functional purpose (e.g. If the productwill have its function compromised by the removal of this secondary
component, then this component also needs to be certified).
Packaging that is made from forest-based inputs (e.g. paper, wood, etc.) is
considered a separate element from the product inside. Therefore, theorganization can choose to certify only the packaging or its content
individually, or both.
The FSC label generator allows the creation of labels with specific producttype claims (e.g. wood, paper, packaging). Thus, in cases where, theproduct contains wood and paper components that are clearly separate
elements, the organization can opt to certify them independently, provided
that the appropriate product type claims is applied on the FSC label. To
avoid risks of misinterpretation in relation to which components of the
product are certified, an additional clarification statement is recomended.
The table below provides some examples of practical application of thisadvice and it is not expected to cover all range of FSC certified products:
Examples of
products

Matches &Matchbox

Games

Which components of a product need to be certified?
Yes
Matches
Optional
Box
Rationale: Matches and matchbox are distinguishable
components that can be certified independently when the
FSC label claim is sufficiently clear to avoid
misinterpretations. However, when the matches andmatchbox are made with the same material (e.g. paper),both shall be certified in order to carry the FSC label.
Yes
Paper and wood components
Optional
Instructions manual
Optional
Packaging
Rationale: The wood and paper components of the gamehave a functional purpose and therefore are the

FSC-DIR-40-004 COC DIRECTIVE2015– 13 of 19 –Books

Notebooks

Magazines

Toilet Paper

Boxes ofTissues

Furniturecomponents that require certification. However, a more
flexible approach is also possible with the condition thatthe proper label statement is applied. For example, when
only the wood components are certified, the FSC label
shall contain the claim “wood” and the paper components
don’t need to be certified. On the other hand, when only
the paper components are certified, the FSC label shallcontain the claim “paper” and the wood components don’t
need to be certified. The instructions manual andpackaging are not product components and for this reason
don’t need to be certified.
Yes
Cover
Yes
Internal paper
Optional
Dust jacket and slip cases
Optional
Wraparound band
Rationale: The cover and internal paper are needed forthe accomplishment of the product’s function, and for thisreason shall be certified. Additional items such as dust
jackets, slip cases and wraparound band are notnecessary for the acomplishment of the product’s funtion
and therefore don’t need to be certified.
Yes
Cover
Yes
Adhesive paper sheets
Yes
Internal paper
Rationale: Notebook cover, internal paper, adhesive
paper sheets are permanent product components and areneeded for the accomplishment of the product’s function.
Therefore, all these components shall be certified.
Yes
Cover
Yes
Internal Paper
Optional
Inserts
Optional
Detachable promotional stickers
Rationale: Magazine cover and its internal paper are
needed for the accomplishment of the product’s function
and therefore shall be certified. Inserts and detachable
promotional stickers are not needed for theaccomplishment of the product’s function and therefore,
independently of the fixation method (bounded, glued,
loose, etc.), don’t need to be certified.
Yes
Toilet paper
Optional
Cardboard roll
Rationale: The toilet paper is the component seeked by
the consumer to fulfil its specific need. The cardboard roll
is a method of dispensing or transporting the paper andcan be separated from the product without compromising
its function. For this reason, the cardboard roll does notneed to be certified. The same rationale applies for all
paper products sold in rolls and bobbins (e.g. paper
bobbins, rolled thermal paper, paper towels).
Tissues
Yes
Optional
Box
Rationale: The tissue paper is the component seeked by
the consumer to fulfil its specific need. The box is amethod of dispensing or transporting the paper and canbe separated from the product without compromising its
function. For this reason, the box doesn‘t need to becertified.
Yes
Furniture

FSC-DIR-40-004 COC DIRECTIVE2015– 14 of 19 –

Adhesive
Labels in
SheetsPrefabricatedhouses(or entire
houses soldas an unit)

Wood
flooring withpaper orveneerinlays

Optional
Packaging
Optional
Price tag or promotional label
Rationale: The furniture is the component seeked by the
consumer to fulfil its specific need. The packaging, pricetag and promotional label have secondary functions in the
product and can be separated from the furniture withoutcompromising its function. For this reason, the packaging
and price tag or promotional label doesn‘t need to becertified.
Yes
Stickers
Optional
Release paper
Rationale: The sticker is the product seeked by the
consumer and the release paper has a secondary function(transporting the product). Therefore, the release paper
doesn’t need to be certified.
Yes
Permanent structural components of thehouse, including flooring, roof, walls, stairs,
windows and doors.
Optional
Other secondary wood elements (e.g.
furniture, cabinets, toilet seats, shelves,
fences, wall paper).
Rationale: A house sold as a unit can be claimed as an
FSC certified product if all permanent structuralcomponents made with forest-based materials that areadded to the house to fulfil the specific consumer’s need(a place to live in) are certified. Other secondary woodelements (e.g. furniture, cabinets, toilet seats, shelves,
fences, wall paper) are not permanent components of thehouse. Therefore, they don’t need to be certified. Houses
made with non-forest based materials (e.g. bricks) thathave specific wooden components (e.g. doors, flooring)incorporated cannot be claimed as an FSC certified
house. However, the organization can label and promotethese components individually; identifying the FSC
certified elements to the consumers.
Yes
Wood
Yes
Paper or veneer inlays
Rationale: The wood and paper/veneer inlays are notdistinguishable elements by consumers and cannot be
separated without compromising the products function.
Therefore, both the wood and paper or veneer inlays shallbe certified in order to claim the flooring as a FSC certified
product.

ADVICE-40-004-07

Sale of FSC certified products through non-FSC certified
auction entities

Normative reference

FSC-STD-40-004, Scope and Clause 6.1

Effective date

30 March 2011

Terms & definitions

Auction: A process of buying and selling goods or services by offering themup for bid, taking bids, and then selling to the winning (generally highest)
bidder. The auction house, auctioneer, log market, etc., managing theauction does not gain legal ownership of the goods/services for sale but
does collect the funds due and issues the sales invoice to the winningbidder.

Background

This advice aims to provide clarification on whether or not auction houses,
log markets or other related entities need to be certified. If so, define the

FSC-DIR-40-004 COC DIRECTIVE
2015– 15 of 19 –

required procedures in order to ensure the traceability of the products
traded by these organizations.
FSC-STD-40-004 establishes that Chain of Custody certification is required
for all organizations that want to produce and sell FSC-certified materials or products; or produce and promote FSC-certified products; or trade materials or products with FSC claims.
NOTE: Chain of Custody certification is not required for organizations that
do not gain legal ownership of such materials or products but simply
arrange for buyer and seller:a) to make a deal without taking physical possession (often called an‘agent’); orb) to transport the materials or products.
AdviceAuctioning entities that do not gain legal ownership of FSC certified
products during trading activities are not required to be FSC chain ofcustody certified, even when the auctioning entity takes physical possessionof the product.
Non-certified entities are not permitted to include FSC claims or certification
codes on their own sales or transport documents.
In order for the customer (winning bidder) to consider material purchased
through a non-FSC certified auction entity as FSC certified, asupplementary letter or transport document must be provided by thecertified supplier to the customer including all information required by FSCSTD-40-004 V2-0, 6.1.1.

ADVICE-40-004-08

Non-conforming product

Normative reference

FSC-STD-40-004 V2-1 Clauses 1.2.1 and 10.1.1

Effective date

01 November 2012
Amended 27 February 2013

Terms & definitions

Non-conforming product: Product or material for which an organization isunable to demonstrate that it complies with FSC eligibility requirements formaking claims and/ or for using the FSC on-product labels.

Background

AdviceSmall COC enterprises: Organizations with:i.
No more than 15 employees (full time equivalent), orii.
No more than 25 employees (full time equivalent) and amaximum total annual turnover of US$ 1,000,000.
Implementation of Chain of Custody procedures and control systems as
required by FSC-STD-40-004 aim to ensure that non-conforming products
do not occur. This advice introduces an additional safeguard to prevent
non-certified products from being delivered as certified, by requiring thatprocedures are put in place to handle non-conforming products.
Specific requirements are included to apply to cases where non-conforming
products are detected after they have been supplied to a customer.
The action taken to address the issue of non-conforming product is targetedto the organization that is responsible for the nonconformity, but it may also
affect onward buyers and sellers e.g. in the event that a product is re-called.
1. The organization shall have a documented procedure defining thecontrols and related responsibilities and authorities for dealing with
non-conforming products. The organization’s chain of custodysystem shall be designed to ensure that products which do notconform to FSC requirements are identified and controlled toprevent its unintended delivery.

FSC-DIR-40-004 COC DIRECTIVE
2015– 16 of 19 –

NOTE: Small COC enterprises are not required to have theprocedure in writing.
2. In case non-conforming products are detected after they have beendelivered, the organization shall:a) immediately cease to sell any non-conforming products held instock;b) identify all relevant customers, and advise those customers inwriting within three (3) business days of the non-conforming
product and maintain records of that advice;c) analyse causes for occurrence of non-conforming products andimplement measures to prevent its re-occurrence.
d) notify their certification body;e) cooperate with the certification body in order to allow thecertification body to confirm that appropriate action is taken tocorrect this non-compliance.

ADVICE-40-004-09

Minor components

StatusWithdrawn

ADVICE-40-004-10

Access to information required by timber legality legislations

Normative reference

FSC-STD-40-004 V2-1, 1.4 and 2.1.1

Effective date

01 November 2012
Amended 27 February 2013

BackgroundIn early 2012, following a mandate of the FSC Board of Directors, FSC
initiated an updating process of its standards to ensure harmonization with
the EU Timber Regulation (EUTR) and other timber legality legislations
such as the US Lacey Act, FLEGT and the Australian Illegal Logging
Prohibition Act. This process includes adjustments in the FSC COC
requirements to ensure that FSC certified products comply with legallyrequired information regarding species, origin of timber and timber products
and compliance with trade and custom laws which include, but may not be
restricted to:• Bans, quotas and other restrictions on the export of timber
products (e.g. bans on the export of unprocessed logs or roughsawn lumber)• Requirements for export licences for timber and timber products• Official authorisation that entities exporting timber and timber
products may require• Taxes and duties applying to timber product exports

Advice1.

Upon request, FSC certified suppliers shall provide customers with thefollowing information about FSC certified and FSC Controlled Woodtimber or timber products subject to compliance with applicable timber
legality legislations:a) Common name and/or scientific name of timber species as
required by the applicable legislation;
NOTE: This requirement takes precedence over Clause 2.1.1 c) of
FSC-STD-40-004 V2-1.
b) Origin of timber (countries of harvest and where applicable, subnational regions and concessions of harvest);
NOTE: Information on the sub-national regions or concessions of

FSC-DIR-40-004 COC DIRECTIVE
2015– 17 of 19 –

harvest shall be provided where the risk of illegal harvesting between
concessions of harvest in a country or sub-national region varies. Any
arrangement conferring the right to harvest timber in a defined area
shall be considered a concession of harvest.
c) Proof of compliance with relevant trade and customs laws.
2.

FSC certified suppliers shall provide timely responses to theinformation requests specified in Clause 1 above.

3.

The form and frequency of providing this information may be agreed
between FSC certified supplier and customer, as long as theinformation is accurate and can be correctly associated with eachmaterial supplied as FSC certified or FSC Controlled Wood.

4.

In case the FSC certified supplier does not possess the requested
information specified in Clause 1 above, the request shall be passed
on to the upstream FSC certified suppliers, until the requested
information can be obtained.

ADVICE-40-004-11

Trade and customs laws

Normative reference

FSC-STD-40-004 V2-1, 1.2

Effective date

27 February 2013.

BackgroundIn early 2012, following a mandate of the FSC Board of Directors, FSC
initiated an updating process of its standards to ensure harmonization with
the EU Timber Regulation (EUTR) and other timber legality legislations
such as the US Lacey Act, FLEGT and the Australian Illegal Logging
Prohibition Act. This process includes adjustments in the FSC COC
requirements to ensure that FSC certified products comply with applicable
trade and custom laws which include, but may not be restricted to:• Bans, quotas and other restrictions on the export of timber products(e.g. bans on the export of unprocessed logs or rough-sawn lumber)• Requirements for export licences for timber and timber products• Official authorisation that entities exporting timber and timber products
may require• Taxes and duties applying to timber product exports.
FSC certificate holders exporting and/or importing timber or timber products
shall have procedures in place to ensure that the commercialization of FSC
certified products comply with all applicable trade and custom laws.

Advice

ADVICE-40-004-12

Pre-consumer reclaimed wood compliance with the EUTR

Normative reference

FSC-STD-40-004 V2-1 Clause 3.3.1

Effective date

01 October 2014.

Terms & definitions

Pre-consumer reclaimed material: Material that is reclaimed from aprocess of secondary manufacture or further downstream industry, in which
the material has not been intentionally produced, is unfit for end use and is
not capable of being re-used on-site in the same manufacturing processthat generated it.
Europe: in the context of this Advice, this refers to the European countries
that fall within the scope of EU Regulation No 995/2010 (known as “EU
Timber Regulation”).

BackgroundIn 2012, following a mandate from the FSC Board of Directors, FSC initiateda revision process of its standards to ensure harmonization with the EU
Timber Regulation (EUTR). According to the EUTR, reclaimed wood suchas sawdust and chips are not classified as waste, and are therefore subject

FSC-DIR-40-004 COC DIRECTIVE
2015– 18 of 19 –

to compliance with the regulation. Paper scraps are currently excluded fromthe scope of the EUTR. As a result of this revision, FSC identified the needto introduce requirements for the control of pre-consumer reclaimed wood inorder to ensure FSC certified products comply with the EUTR, for products
placed on the European market.
Advice1

FSC certificate holders placing FSC certified products containing
pre-consumer reclaimed wood material (except paper scraps) on
the European market for the first time shall exercise due diligence
to ensure that these materials do not contain illegally harvested
timber according to EU Regulation No 995/2010.

2

FSC certificate holders located in countries outside of Europe andexporting FSC certified products that contain pre-consumer
reclaimed wood material to companies in Europe shall either:3a) Inform their customers about the presence of pre-consumer
reclaimed wood material in the product before its delivery andcommit to support their customers in applying their due
diligence system, as required by the EUTR, or;b) Ensure that pre-consumer reclaimed wood (except paper
scraps) used in the manufacturing of FSC certified products is
FSC Controlled Wood, according to FSC-STD-40-005
requirements.
FSC certificate holders applying option 2 b) above, may apply therequirements for co-products outlined in the ADVICE-40-005-17, todemonstrate the district of origin of pre-consumer reclaimed woodand the ADVICE-40-005-20 for the risk assessment of preconsumer reclaimed wood.

ADVICE-40-004-13

Classification of pre-consumer reclaimed paper as equivalent to
FSC certified and post-consumer reclaimed materials

Normative reference

FSC-STD-40-004 V2-1, Clauses 8.2.1, 8.3.1, 9.2.1, 9.3.1 and Footnote 4

Effective date

07 October 2015

BackgroundAt the FSC General Assembly in 2011, the FSC membership mandated
FSC to conduct a chamber-balanced study to evaluate the risks andbenefits of valuing pre-consumer reclaimed paper fibre materials as FSC
certified content (Motion 38). The results of the study and consultation
feedback demonstrated the FSC membership support to the proposal.
At its 66th meeting in July 2014 the FSC Board approved the proposal toclassify pre-consumer reclaimed paper to count as equivalent to FSC
certified and post-consumer reclaimed materials for the purpose ofpercentage and credit claims calculations. PSU was instructed to implement
this decision through the incorporation into the revision process of FSCSTD-40-004. As this revision is delayed the Board approved this Advice
Note to bring the decision forward and to allow companies to start applying
it. This Advice Note will be withdrawn at the effective date of FSC-STD-40004 V3-0.

AdviceFSC CoC certificate holders may classify pre-consumer reclaimed papermaterials as equivalent to FSC certified and post-consumer reclaimed
materials for the purpose of determining the FSC Mix or FSC Recycled
output claims for products controlled under the percentage or credit system.

FSC-DIR-40-004 COC DIRECTIVE
2015– 19 of 19 –